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SEC Petition Evaluation Report

Petition SEC-00154 

Revision 1

Report Rev #: 1 Report Submittal Date: November 22, 2011 

Subject Expert(s): Frank C. Crawford

Site Expert(s): N/A

Petition Administrative Summary

Petition Under Evaluation

Petition # Petition 

Type

Petition

Receipt Date

Qualification 

Date

DOE/AWE Facility Name

SEC-00154 83.13 November 5, 2009 January 22, 2010 Linde Ceramics Plant

Petitioner Class Definition 

All employees who worked in any area at Linde Ceramics in Tonawanda, New York, from November 1, 1947 

through December 31, 1953.

Class Evaluated by NIOSH

All employees who worked in any area at the Linde Ceramics Plant in Tonawanda, New York, from November 1, 

1947 through December 31, 1953.

NIOSH-Proposed Class(es) to be Added to the SEC

All employees who worked in any area at the Linde Ceramics Plant in Tonawanda, New York, from November 1, 

1947 through December 31, 1953, for a number of work days aggregating at least 250 work days, occurring either 

solely under this employment or in combination with work days within the parameters established for one or more 

of the classes of employees in the Special Exposure Cohort.

Related Petition Summary Information 

SEC Petition Tracking #(s) Petition Type DOE/AWE Facility Name Petition Status

SEC-00044

SEC-00106 

SEC-00107 

SEC-00112 

SEC-00127

83.14

83.13 

83.13 

83.13 

83.13

Linde Ceramics Plant

Linde Ceramics Plant

Linde Ceramics Plant

Linde Ceramics Plant

Linde Ceramics Plant

SEC class 1942-47

Closed

Sent to Board 

Merged w/SEC-00107 

Merged w/SEC-00107

Related Evaluation Report Information 

Report Title DOE/AWE Facility 

Name

SEC Petition Evaluation Report for SEC-00044

SEC Petition Evaluation Report for SEC-00107

Linde Ceramics Plant

Linde Ceramics Plant

ORAU Lead Technical Evaluator: Jason Davis ORAU Peer Review Completed By: Daniel Stempfley

Peer Review Completed By: [Signature on File] 11/22/2011

LaVon B. Rutherford Date

[Signature on File] 11/22/2011 SEC Petition Evaluation Reviewed By:

J. W. Neton Date

[Signature on File] 11/22/2011 SEC Evaluation Approved By:

Stuart Hinnefeld Date
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Evaluation Report Summary: SEC-00154, Linde Ceramics

This evaluation report by the National Institute for Occupational Safety and Health (NIOSH)

addresses a class of employees proposed for addition to the Special Exposure Cohort (SEC) per the 

Energy Employees Occupational Illness Compensation Program Act of 2000, as amended, 42 U.S.C. 

§ 7384 et seq. (EEOICPA) and 42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as 

Members of the Special Exposure Cohort under the Energy Employees Occupational Illness 

Compensation Program Act of 2000. 

Petitioner-Requested Class Definition

Petition SEC-00154 was received on November 05, 2009, and qualified on January 19, 2010. The 

petitioner requested that NIOSH consider the following class: All employees who worked in any area 

at Linde Ceramics in Tonawanda, New York, from November 1, 1947 through December 31, 1953. 

Class Evaluated by NIOSH

Based on its preliminary research, NIOSH accepted the petitioner-requested class. NIOSH evaluated 

the following class: All employees who worked in any area at the Linde Ceramics Plant in 

Tonawanda, New York, from November 1, 1947 through December 31, 1953. 

NIOSH-Proposed Class to be Added to the SEC 

This evaluation defines a single class of employees for which NIOSH cannot estimate radiation doses 

with sufficient accuracy. This class includes all employees who worked at the Linde Ceramics Plant 

in Tonawanda, New York, from November 1, 1947 through December 31, 1953, for a number of work 

days aggregating at least 250 work days, occurring either solely under this employment or in 

combination with work days within the parameters established for one or more of the classes of 

employees in the Special Exposure Cohort. 

Feasibility of Dose Reconstruction

NIOSH has documented in this evaluation that it could not complete the dose reconstruction related to 

this petition. The basis of this finding is specified in this report, which demonstrates that NIOSH 

lacks access to sufficient information to estimate either the maximum radiation dose incurred by any 

member of the class or to estimate such doses more precisely than a maximum dose estimate. 

Members of this class may have received internal and external exposures from uranium and/or 

uranium progeny from the ores and refined uranium processed at the plant. NIOSH lacks sufficient 

biological, air monitoring, and source-term data to estimate the potential airborne concentrations to 

which the proposed class may have been exposed. 

The NIOSH dose reconstruction feasibility findings are based on the following: 

• Principal sources of internal and external radiation for members of the proposed class included 

exposures to production quantities of uranium oxides and fluorides as well as site contamination 

from earlier production periods containing uranium and uranium progeny, including radon. 
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• There are currently two classes of Linde Ceramics workers associated with the previous NIOSH 

evaluations of SEC petition SEC-00044 for a portion of the site’s Atomic Weapons Employer 

operations period (October 1, 1942 through October 31, 1947) and SEC Petitition SEC-00107 for 

a portion of the site’s residual period (January 1, 1954 through December 31, 1969). The 

Secretary of the Department of Health and Human Services has designated the following classes

for inclusion in the Special Exposure Cohort: 

 Atomic weapons employees who worked at the Linde Ceramics Plant from October 1, 

1942, through October 31, 1947, and who were employed for a number of work days 

aggregating at least 250 work days, either solely under this employment or in 

combination with work days of employment occurring within the parameters 

(excluding aggregate work day requirements) established for other classes of 

employees included in the SEC 

 All Atomic Weapons Employees who worked at the Linde Ceramics Plant in 

Tonawanda, New York, from January 1, 1954 through December 31, 1969, for a 

number of work days aggregating at least 250 work days, occurring either solely under 

this employment, or in combination with work days within the parameters established 

for one or more other classes of employees in the SEC

• The period currently being evaluated, November 1, 1947 through December 31, 1953, follows 

immediately after the already-designated SEC-00044 period for Linde Ceramics Plant. NIOSH 

has determined that Linde Ceramics Plant continued to process radioactive material and to 

decontaminate associated buildings of the Linde Ceramics Plant that could have resulted in the 

generation of airborne dust, surface contamination, and direct contact with bulk materials. The 

potential for unmonitored exposures continued at Linde Ceramics Plant until site AWE operations 

concluded in 1953. 

• NIOSH does not have access to sufficient personnel monitoring, workplace monitoring, or source 

term data to estimate unmonitored internal exposures for Linde Ceramics Plant workers during the 

period from November 1, 1947 through December 31, 1953. 

• Pursuant to 42 C.F.R. § 83.13(c)(1), NIOSH determined that there is insufficient information to 

either: (1) estimate the maximum radiation dose, for every type of cancer for which radiation 

doses are reconstructed, that could have been incurred under plausible circumstances by any 

member of the class; or (2) estimate the radiation doses of members of the class more precisely 

than a maximum dose estimate.

• Although NIOSH found that it is not possible to completely reconstruct radiation doses for the 

proposed class, NIOSH intends to use any internal and external monitoring data that may become 

available for an individual claim (and that can be interpreted using existing NIOSH dose 

reconstruction processes or procedures). Therefore, dose reconstructions for individuals employed 

at Linde Ceramics Plant during the period from November 1, 1947 through December 31, 1953, 

but who do not qualify for inclusion in the SEC, may be performed using these data as 

appropriate. 
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• NIOSH finds that it is likely feasible to reconstruct occupational medical dose for Linde workers 

with sufficient accuracy, for the period from January 1, 1950 through December 31, 1953. 

Health Endangerment Determination

Per EEOICPA and 42 C.F.R. § 83.13(c)(3), a health endangerment determination is required because 

NIOSH has determined that it has insufficient information to estimate dose for the members of the 

evaluated class.

The NIOSH evaluation did not identify evidence from the petitioner or from other resources that 

would establish that the class was exposed to radiation during a discrete incident likely to have 

involved exceptionally high level exposures. The evidence reviewed in this evaluation indicates that 

some workers in the class may have accumulated substantial chronic exposures through episodic 

intakes of radionuclides. Consequently, NIOSH has specified that health was endangered for those 

workers covered by this evaluation who were employed for a number of work days aggregating at 

least 250 work days, occurring solely under this employment or in combination with work days within 

the parameters established for one or more other classes of employees in the Special Exposure Cohort. 
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Table of Contents

1.0 Purpose and Scope .......................................................................................................................... 9

2.0 Introduction .................................................................................................................................... 9

3.0 SEC-00154, Linde Ceramics Plant Class Definitions .................................................................. 10

3.1 Petitioner-Requested Class Definition and Basis ................................................................ 10

3.2 Class Evaluated by NIOSH ................................................................................................. 11

3.3 NIOSH-Proposed Class to be Added to the SEC ................................................................ 11

4.0 Data Sources Reviewed by NIOSH to Evaluate the Class ........................................................... 11

4.1 Site Profile Technical Basis Documents (TBDs) ................................................................ 12

4.2 Technical Information Bulletins (TIBs) and Procedures ..................................................... 12

4.3 Facility Employees and Experts .......................................................................................... 13

4.4 Previous Dose Reconstructions ........................................................................................... 13

4.5 NIOSH Site Research Database .......................................................................................... 14

4.6 Documentation and/or Affidavits Provided by Petitioners ................................................. 14

5.0 Radiological Operations Relevant to the Class Evaluated by NIOSH ......................................... 15

5.1 Linde Ceramics Plant and Process Descriptions ................................................................. 15

5.2 Radiological Exposure Sources from Linde Ceramics Plant Operations ............................ 19

5.2.1 Internal Radiological Exposure Sources from Linde Ceramics Plant Operations .. 19

5.2.2 External Radiological Exposure Sources from Linde Ceramics Plant Operations . 20

5.2.2.1 Photon ....................................................................................................... 20

5.2.2.2 Beta ........................................................................................................... 20

5.2.2.3 Neutron ..................................................................................................... 21

6.0 Summary of Available Monitoring Data for the Class Evaluated by NIOSH ............................. 21

6.1 Available Linde Ceramics Plant Internal Monitoring Data ................................................. 21

6.2 Available Linde Ceramics Plant External Monitoring Data ................................................ 22

6.3 Available Linde Ceramics Plant Utility Tunnel External Monitoring Data ........................ 23

7.0 Feasibility of Dose Reconstruction for the Class Evaluated by NIOSH ...................................... 24

7.1 Pedigree of Linde Ceramics Plant Data ............................................................................... 24

7.1.1 Internal Monitoring Data Pedigree Review ............................................................. 25

7.1.2 External Monitoring Data Pedigree Review ............................................................ 25

7.2 Evaluation of Bounding Internal Radiation Doses at Linde Ceramics Plant ...................... 26

7.2.1 Evaluation of Bounding Process-Related Internal Doses ........................................ 26

7.2.1.1 Urinalysis Information and Available Data .............................................. 26

7.2.1.2 Airborne Levels ........................................................................................ 27

7.2.2 Evaluation of Bounding Ambient Environmental Internal Doses ........................... 28

7.2.3 Methods for Bounding Internal Dose at Linde Ceramics Plant .............................. 28

7.2.3.1 Methods for Bounding Internal Dose for Site Workers ........................... 28

7.2.3.2 Methods for Bounding Internal Radon Dose for Site Workers ................ 29

7.2.4 Internal Dose Reconstruction Feasibility Conclusion ............................................. 29
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7.3 Evaluation of Bounding External Radiation Doses at Linde Ceramics Plant ..................... 30

7.3.1 Evaluation of Bounding Process-Related External Doses ....................................... 30

7.3.1.1 Personnel Dosimetry Data ........................................................................ 30

7.3.1.2 Alternative Data Sources for Bounding External Dose ............................ 31

7.3.2 Evaluation of Bounding Ambient Environmental External Doses .......................... 31

7.3.3 Linde Ceramics Plant Occupational X-Ray Examinations ..................................... 31

7.3.4 Methods for Bounding External Dose at Linde Ceramics Plant ............................. 32

7.3.5 External Dose Reconstruction Feasibility Conclusion ............................................ 33

7.4 Evaluation of Petition Basis for SEC-00154 ....................................................................... 33

7.4.1 Lack of Individual Monitoring ................................................................................ 33

7.4.2 Adequacy of Data .................................................................................................... 33

7.5 Other Potential SEC Issues Relevant to the Petition Identified During the Evaluation ...... 34

7.6 Summary of Feasibility Findings for Petition SEC-00154 .................................................. 35

8.0 Evaluation of Health Endangerment for Petition SEC-00154 ...................................................... 35

9.0 Class Conclusion for Petition SEC-00154 ................................................................................... 36

10.0 References .................................................................................................................................... 37

Attachment One: Data Sources on Uranium Progeny Concentrations in Linde Materials ................... 45

Attachment Two: Data Capture Synopsis ............................................................................................. 46

Tables 

Table 4-1: No. of Linde Ceramics Plant Claims Submitted Under the Dose Reconstruction Rule ...... 13

Table 5-1: Activities and Operations at Linde Ceramics ...................................................................... 16

Table 5-2: Types of Feed Material Used in the Linde Ceramics Operation ......................................... 17

Table 5-3: Linde Ceramics Timeline for the Period Under Evaluation ................................................ 19

Table 6-1: Number of Available Linde Bioassay Records Per Year ..................................................... 21

Table 6-2: Number of Available Air Monitoring Records Per Year ..................................................... 22

Table 6-3: Radionuclide Fraction Calculation Using Average Linde Soil Concentrations .................. 23

Table 7-1: Summary of Feasibility Findings for SEC-00154 ............................................................... 35
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SEC Petition Evaluation Report for SEC-00154

1.0 Purpose and Scope

This report evaluates the feasibility of reconstructing doses for all employees who worked in any area 

at the Linde Ceramics Plant in Tonawanda, New York, from November 1, 1947 through December 

31, 1953. It provides information and analyses germane to considering a petition for adding a class of 

employees to the congressionally-created SEC. 

This report does not make any determinations concerning the feasibility of dose reconstruction that 

necessarily apply to any individual energy employee who might require a dose reconstruction from 

NIOSH. This report also does not contain the final determination as to whether the proposed class 

will be added to the SEC (see Section 2.0). 

This evaluation was conducted in accordance with the requirements of EEOICPA, 42 C.F.R. pt. 83, 

and the guidance contained in the Division of Compensation Analysis and Support’s (DCAS) Internal 

Procedures for the Evaluation of Special Exposure Cohort Petitions, OCAS-PR-004.1

2.0 Introduction 

Both EEOICPA and 42 C.F.R. pt. 83 require NIOSH to evaluate qualified petitions requesting that the 

Department of Health and Human Services (HHS) add a class of employees to the SEC. The 

evaluation is intended to provide a fair, science-based determination of whether it is feasible to 

estimate with sufficient accuracy the radiation doses of the class of employees through NIOSH dose 

reconstructions.2 

42 C.F.R. § 83.13(c)(1) states: Radiation doses can be estimated with sufficient accuracy if NIOSH 

has established that it has access to sufficient information to estimate the maximum radiation dose, 

for every type of cancer for which radiation doses are reconstructed, that could have been incurred in 

plausible circumstances by any member of the class, or if NIOSH has established that it has access to 

sufficient information to estimate the radiation doses of members of the class more precisely than an 

estimate of the maximum radiation dose.

 

Under 42 C.F.R. § 83.13(c)(3), if it is not feasible to estimate with sufficient accuracy radiation doses 

for members of the class, then NIOSH must determine that there is a reasonable likelihood that such 

radiation doses may have endangered the health of members of the class. The regulation requires 

NIOSH to assume that any duration of unprotected exposure may have endangered the health of 

members of a class when it has been established that the class may have been exposed to radiation 

during a discrete incident likely to have involved levels of exposure similarly high to those occurring 

during nuclear criticality incidents. If the occurrence of such an exceptionally high-level exposure has 

not been established, then NIOSH is required to specify that health was endangered for those workers 

who were employed for at least 250 aggregated work days within the parameters established for the 

 

1 DCAS was formerly known as the Office of Compensation Analysis and Support (OCAS).

2 NIOSH dose reconstructions under EEOICPA are performed using the methods promulgated under 42 C.F.R. pt. 82 and 

the detailed implementation guidelines available at http://www.cdc.gov/niosh/ocas.
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class or in combination with work days within the parameters established for other SEC classes 

(excluding aggregate work day requirements). 

NIOSH is required to document its evaluation in a report, and to do so, relies upon both its own dose 

reconstruction expertise as well as technical support from its contractor, Oak Ridge Associated 

Universities (ORAU). Once completed, NIOSH provides the report to both the petitioner(s) and to the 

Advisory Board on Radiation and Worker Health (Board). The Board will consider the NIOSH 

evaluation report, together with the petition, petitioner(s) comments, and other information the Board 

considers appropriate, in order to make recommendations to the Secretary of HHS on whether or not 

to add one or more classes of employees to the SEC. Once NIOSH has received and considered the 

advice of the Board, the Director of NIOSH will propose a decision on behalf of HHS. The Secretary 

of HHS will make the final decision, taking into account the NIOSH evaluation, the advice of the 

Board, and the proposed decision issued by NIOSH. As part of this decision process, petitioners may 

seek a review of certain types of final decisions issued by the Secretary of HHS.

3

 

3.0 SEC-00154, Linde Ceramics Plant Class Definitions 

The following subsections address the evolution of the class definition for SEC-00154, Linde 

Ceramics Plant. When a petition is submitted, the requested class definition is reviewed as submitted. 

Based on its review of the available site information and data, NIOSH will make a determination 

whether to qualify for full evaluation all, some, or no part of the petitioner-requested class. If some 

portion of the petitioner-requested class is qualified, NIOSH will specify that class along with a 

justification for any modification of the petitioner’s class. After a full evaluation of the qualified 

class, NIOSH will determine whether to propose a class for addition to the SEC and will specify that 

proposed class definition. 

3.1 Petitioner-Requested Class Definition and Basis

Petition SEC-00154 was received on November 5, 2009, and qualified on January 22, 2010. The 

petitioner requested that NIOSH consider the following class: All employees who worked in any area 

at Linde Ceramics in Tonawanda, New York, from November 1, 1947 through December 31, 1953. 

The petitioner provided information and affidavit statements in support of the petitioner’s belief that 

accurate dose reconstruction over time is impossible for the Linde workers in question. NIOSH 

deemed the following information and affidavit statements sufficient to qualify SEC-00154 for 

evaluation: 

The petition and its ten supporting documents, including four affidavits from two former workers 

and NIOSH interviews with two former workers, were intended to support the petition bases F.1 

and F.3. NIOSH’s review of the petition documentation found insufficient support for these bases

in those documents for the petitioner-proposed class. However, based on its research and reviews 

of available information and documentation conducted to date for the Linde Ceramics Plant, 

NIOSH determined that although internal and external monitoring was performed for members of 

the petitioner-proposed class, this monitoring did not adequately assess all potential exposures or 

 

3 See 42 C.F.R. pt. 83 for a full description of the procedures summarized here. Additional internal procedures are 

available at http://www.cdc.gov/niosh/ocas.
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exposure periods. Based on this information, NIOSH concluded that the F.1 basis is sufficiently 

supported. 

Based on its Linde Ceramics Plant research and data capture efforts, NIOSH determined that it has 

access to area monitoring, exposure scenario information, personnel dosimetry data, and internal 

dosimetry data for Linde Ceramics Plant workers during the time period under evaluation. However, 

NIOSH also determined that internal and external personnel monitoring records are not complete for 

all time periods or for all radionuclides. NIOSH concluded that there is sufficient documentation to 

support, for at least part of the requested time period, the petition basis that internal and external 

radiation exposures and radiation doses were not adequately monitored at Linde Ceramics, either 

through personal monitoring or area monitoring. The information and statements provided by the 

petitioner qualified the petition for further consideration by NIOSH, the Board, and HHS. The details 

of the petition basis are addressed in Section 7.4. 

3.2 Class Evaluated by NIOSH

Based on its preliminary research, NIOSH accepted the petitioner-requested class because NIOSH 

was unable to locate personal and area monitoring data for portions of the proposed time period and 

has reason to believe, based on the nature of activities during the time period following the cessation 

of operations, that workers were unmonitored during a portion of the period under evaluation. 

Therefore, NIOSH defined the following class for further evaluation: All employees who worked at 

the Linde Ceramics plant in Tonawanda, New York, from November 1, 1947 through December 31, 

1953. 

3.3 NIOSH-Proposed Class to be Added to the SEC

Based on its research, NIOSH has obtained urinalysis data, personnel monitoring data, air monitoring 

data, and contamination survey data specific to the Linde Ceramics Plant. After careful review of 

these data, NIOSH has determined that the available data are insufficient to bound exposures for 

members of the class under evaluation. 

This class includes employees who worked at the Linde Ceramics Plant in Tonawanda, New York, 

from November 1, 1947 through December 31, 1953, for a number of work days aggregating at least 

250 work days, occurring either solely under this employment or in combination with work days 

within the parameters established for one or more of the classes of employees in the Special Exposure 

Cohort. 

4.0 Data Sources Reviewed by NIOSH to Evaluate the Class

As a standard practice, NIOSH completed an extensive database and Internet search for information 

regarding the Linde Ceramics Plant. The database search included the DOE Legacy Management 

Considered Sites database, the DOE Office of Scientific and Technical Information (OSTI) database, 

the Energy Citations database, the Atomic Energy Technical Report database, and the Hanford 

Declassified Document Retrieval System. In addition to general Internet searches, the NIOSH 

Internet search included OSTI OpenNet Advanced searches, OSTI Information Bridge Fielded 

searches, Nuclear Regulatory Commission (NRC) Agency-wide Documents Access and Management 
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(ADAMS) web searches, the DOE Office of Human Radiation Experiments website, and the DOENational Nuclear Security Administration-Nevada Site Office-search. Attachment Two contains a 

summary of Linde Ceramics Plant documents. The summary specifically identifies data capture 

details and general descriptions of the documents retrieved. 

In addition to the database and Internet searches listed above, NIOSH identified and reviewed 

numerous data sources to determine information relevant to determining the feasibility of dose 

reconstruction for the class of employees under evaluation. This included determining the availability 

of information on personal monitoring, area monitoring, industrial processes, and radiation source 

materials. The following subsections summarize the data sources identified and reviewed by NIOSH. 

4.1 Site Profile Technical Basis Documents (TBDs) 

A Site Profile provides specific information concerning the documentation of historical practices at 

the specified site. Dose reconstructors can use the Site Profile to evaluate internal and external 

dosimetry data for monitored and unmonitored workers, and to supplement, or substitute for, 

individual monitoring data. A Site Profile consists of an Introduction and five Technical Basis 

Documents (TBDs) that provide process history information, information on personal and area 

monitoring, radiation source descriptions, and references to primary documents relevant to the 

radiological operations at the site. The Site Profile for a small site may consist of a single document. 

As part of NIOSH’s evaluation detailed herein, it examined the following TBDs for insights into 

Linde Ceramics Plant operations or related topics/operations at other sites: 

• An Exposure Matrix for Linde Ceramics Plant (Including Tonawanda Laboratory), ORAUTTKBS-0025; Rev. 02; July 15, 2011; SRDB Ref ID: 99725 

4.2 Technical Information Bulletins (TIBs) and Procedures

A Technical Information Bulletin (TIB) is a general working document that provides guidance for 

preparing dose reconstructions at particular sites or categories of sites. A procedure provides specific 

requirements and guidance regarding EEOICPA project-level activities, including preparation of dose 

reconstructions at particular sites or categories of sites. NIOSH reviewed the following TIBs and 

procedures as part of its evaluation: 

• TIB: Analysis of Coworker Bioassay Data for Internal Dose Assignment, ORAUT-OTIB-0019, 

Rev. 01; October 7, 2005; SRDB Ref ID: 19438

• TIB: Estimation of Neutron Dose Rates from Alpha-Neutron Reactions in Uranium and Thorium 

Compounds, ORAUT-OTIB-0024, Rev. 00; April 07, 2005; SRDB Ref ID: 19445

• TIB: Dose Reconstruction During Residual Radioactivity Periods at Atomic Weapons Employer 

Facilities, ORAUT-OTIB-0070, Rev. 00; March 10, 2008; SRDB Ref ID: 41603
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4.3 Facility Employees and Experts

To obtain additional information, NIOSH interviewed five former Linde Ceramics Plant employees 

and reviewed the eight former Linde employee interviews conducted in 2008 as part of the evaluation 

process for SEC-00107. The NIOSH interviews conducted for the SEC-00154 evaluation included: 

• Personal Communication, 2010a, Telephone Interview by ORAU Team HP; March 4, 2010; 

SRDB Ref ID: 80052

• Personal Communication, 2010b, Telephone Interview by ORAU Team HP; March 4, 2010; 

SRDB Ref ID: 80053

• Personal Communication, 2010c, Telephone Interview by ORAU Team HP; March 10, 2010; 

SRDB Ref ID: 80055

• Personal Communication, 2010d, Telephone Interview by ORAU Team HP; March 10, 2010; 

SRDB Ref ID: 80054

• Personal Communication, 2010e, Telephone Interview by ORAU Team HP; March 11, 2010; 

SRDB Ref ID: 80056

4.4 Previous Dose Reconstructions

NIOSH reviewed its NIOSH DCAS Claims Tracking System (NOCTS) to locate EEOICPA-related 

dose reconstructions that might provide information relevant to the petition evaluation. Table 4-1 

summarizes the results of this review. (NOCTS data available as of November 15, 2011) 

Table 4-1: No. of Linde Ceramics Plant Claims Submitted Under the Dose Reconstruction Rule

Description Totals

Total number of claims submitted for dose reconstruction 273

Total number of claims submitted for energy employees who meet the definition criteria for the class 

under evaluation (November 1, 1947 through December 31, 1953) 144

Number of dose reconstructions completed for energy employees who meet the definition criteria for 

the class under evaluation (i.e., the number of such claims completed by NIOSH and submitted to the 

Department of Labor for final approval). 92 

Number of claims for which internal dosimetry records were obtained for the identified years in the 

evaluated class definition 9 

Number of claims for which external dosimetry records were obtained for the identified years in the 

evaluated class definition 6 

NIOSH reviewed each claim to determine whether internal and/or external personal monitoring 

records could be obtained for the employee. Forty-two of the submitted claims are covered under the 

previously-approved SEC period for Linde Ceramics Plant (NIOSH, 2005). For each of the claims

with dosimetry data, the data were collected during Step III of the Linde uranium separation process 

(the fluorination of UO2 to UF4).
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4.5 NIOSH Site Research Database

NIOSH also examined its Site Research Database (SRDB) to locate documents supporting the 

assessment of the evaluated class. Seven hundred eighty-six documents in this database were 

identified as pertaining to the Linde Ceramics Plant. These documents were evaluated for their 

relevance to this petition. The documents include historical background on the operational process, 

process materials, equipment removal, dust sampling, air monitoring, and site clean-up. 

4.6 Documentation and/or Affidavits Provided by Petitioners

In qualifying and evaluating the petition, NIOSH reviewed the following documents submitted by the 

petitioners:

• Linde Ceramics Special Exposure Cohort Application: November 1, 1947 through December 31, 

1953; SEC petition; received November 5, 2009; OSA Ref ID: 110180 (Petition, 2009)

• Affidavits from Former Linde Ceramics Employees; November 5, 2009; OSA Ref ID: 110180 pp. 

18-22; 27-29 (Affidavits, 2009) 

• SEC-00107 Linde Ceramics Plant Interviews – [Name Redacted]; Interview conducted in support 

of SEC-00107; September 11, 2008; OSA Ref ID: 110180 (SEC-00107 Interview, 2008a)

• SEC-00107 Linde Ceramics Plant Interviews – [Name Redacted]; Interview conducted in support 

of SEC-00107; September 11, 2008; OSA Ref ID: 110180 (SEC-00107 Interview, 2008b)

• Personal Correspondence Between [Name Redacted] and [Name Redacted], Consultant to 

Praxair Inc.; Contains a request for personal records; July 22, 2009; OSA Ref ID: 110180 pdf pp. 

23 (Correspondence, 2009a)

• Personal Correspondence Between [Name Redacted], Consultant to Praxair Inc., and [Name 

Redacted]; response to a request for personal records. Includes a CARDEX work history; August 

19, 2009; OSA Ref ID 110180 pdf pp. 24-26 (Correspondence, 2009b)

• Draft Assessment of the Disposition of SC&A’s Linde Site Profile Review Issues in Response to 

SEC Petitioner Concerns; S. Cohen and Associates (SC&A); August, 2009; OSA Ref ID 110180 

pp. 30-103 (SC&A, 2009)

• Linde Ceramics SEC Petitions Addendum SEC Tracking Numbers: SEC00106 and SEC00107—

Additional Issues and Supplementary Evidence Supporting Linde Ceramics Petitions SEC00106 

and SEC00107; March 28, 2008; OSA Ref ID: 105723 and 105687, pdf pp. 28-33 (Supplementary 

Evidence, 2008a)

• Linde Ceramics SEC Petition Application: November 1, 1947 through December 31, 1953, 

supporting document from the petitioner; March 28, 2008; OSA Ref ID: 105724 and 105687, pdf 

pp. 3-27 (SEC Petition Narrative, 2008) 
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• Additional Issues and Supplementary Evidence Supporting Linde Ceramics SEC Petitions 

SEC00106 November 1, 1947 through December 31, 1953 and SEC00107 January 1, 1954 

through July 31, 2006, supporting document from the petitioner; April 25, 2008; OSA Ref ID: 

105849 (Supplementary Evidence, 2008b) 

• Additional Issues and Supplementary Evidence Supporting Linde Ceramics SEC Petition 

SEC00107 January 1, 1954 through July 31, 2006, supporting document from the petitioner; May 

20, 2008; OSA Ref ID: 106080 (Supplementary Evidence, 2008c) 

5.0 Radiological Operations Relevant to the Class Evaluated by 

NIOSH

ATTRIBUTION: Section 5.0 and its related subsections were completed by Jason Davis and Monica 

Harrison-Maples, Oak Ridge Associated Universities. The rationales for all conclusions in this 

document are explained in the associated text. 

The following subsections summarize both radiological operations at the Linde Ceramics Plant from 

November 1, 1947 through December 31, 1953 and the information available to NIOSH to 

characterize particular processes and radioactive source materials. From available sources NIOSH has 

gathered process and source descriptions, information regarding the identity and quantities of each 

radionuclide of concern, and information describing processes through which radiation exposures may 

have occurred and the physical environment in which they may have occurred. The information 

included within this evaluation report is intended only to be a summary of the available information. 

5.1 Linde Ceramics Plant and Process Descriptions 

During the period from 1942 through 1949, Linde Air Products Corporation (the company that ran the 

Linde Ceramics Plant and the Linde Air Facility in Buffalo, New York) was contracted by the 

Manhattan Engineer District (MED) and its successor the Atomic Energy Commission (AEC) to 

perform uranium separation. Linde Air Products Corporation was selected because of the expertise it 

acquired from working in the ceramics business, processing uranium to produce the black, yellow, 

green, and brown "salts" used for coloring ceramic glazes.

The contracted MED/AEC activities took place at Linde Ceramics Plant in Buildings 14, 30, 31, 37, 

and 38. Building 14 was built by Union Carbide in the mid-1930s. Buildings 30, 31, 37, and 38 were 

built by the MED on land owned by Union Carbide. With the termination of the AEC contract in 

1954, ownership was transferred to Linde Air Products Corporation. Table 5-1 presents Linde 

activities and operations by building. 

Under the MED/AEC contract, seven different sources of uranium were processed at Linde Ceramics: 

four African ores (three low-grade pitchblendes and a torbernite) and three domestic ores (carnotites 

from Colorado). Some of the domestic ores were actually tailings from vanadium processing and 

were pre-processed in order to concentrate the uranium prior to shipment from the western states. The 

majority of the radium in these ores was removed during the pre-processing. The African ores were 

unprocessed and contained all members of the uranium decay series, including radium in secular 
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equilibrium with the uranium. As a result of the radium content, the African ores produced 

substantially higher levels of radon gas than the domestic ores. 

In 1943, following laboratory and pilot-plant studies, uranium processing began at Linde Ceramics. 

The uranium ores and tailings were processed in three steps: Step I involved uranium oxide (U3O8) 

being separated from the feedstock by acid digestion followed by precipitation and filtration. Step II 

involved converting uranium oxide to uranium dioxide. Residues from Step II were recycled to Step 

I. In Step III, uranium dioxide was converted to uranium tetrafluoride (Bechtel, 1990). Table 5-2 

shows the types of feed material used in the Linde Ceramics operation. 

Table 5-1: Activities and Operations at Linde Ceramics

Building Activities/Operations Description

14

Facility: Built in the mid-1930s by Union Carbide. Vacated in March 2004. Demolition began April 30, 

2004.

Operations: Served as a location of laboratory studies. Served as a pilot plant for uranium separation in the 

early part of MED/AEC operations. 

30

Facility: Built by the MED on Union Carbide-owned land. Step II process equipment dismantled starting in 

March 1948; completed in April 1948. Step I process equipment dismantled in stages throughout 1949. 

D&D reported complete as of March 29, 1950. Ownership transferred to Linde Air Products Corporation

with termination of the AEC contract in 1954. Demolished September 5-19, 1998.

Operations: Served as the primary processing building for Step I (ores to U3O8) and Step II (U3O8 to UO2) 

uranium processing during MED/AEC operations. Also used as the location for some processing of 

metallic nickel with nitric acid to produce nickel salt. 

31

Facility: Built by the MED on Union Carbide-owned land. Ownership transferred to Linde Air Products 

Corporation with termination of the AEC contract in 1954. Decontaminated in 1997.

Operations: Served as a location of Step III (fluorination of UO2 to UF4) uranium separation processing 

during MED/AEC operations (November 1, 1947 through June 30, 1949).

37

Facility: Built by the MED on Union Carbide-owned land. Ownership transferred to Linde Air Products 

Corporation with termination of the AEC contract in 1954. Demolished in 1981.

Operations: Used for Step III (fluorination of UO2 to UF4). Although no details have been found, the 16 ft x 

36 ft building footprint indicates a minor role in Step III processes (November 1, 1947 through June 30, 

1949).

38

Facility: Built by the MED on Union Carbide-owned land. D&D began in November 1952. Ownership 

transferred to Linde Air Products Corporation with termination of the AEC contract in 1954. Demolished in 

1996. 

Operations: Served as a location for Step III (fluorination of UO2 to UF4) uranium separation processing 

during MED/AEC operations (November 1, 1947 through June 30, 1949). 

Sources: SEC-00107 E-mail, 2004; Army Corps, 1998; Bechtel, 1993; ORAUT-TKBS-0025, Section 2.6
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Table 5-2: Types of Feed Material Used in the Linde Ceramics Operation

Type of Material Code Time Period when Processed Assay of U3O8

a

Colorado concentrates L-19 June 1943 – November 1943 12% - 14%

African pitchblende L-30 November 1943 – September 1944 8.2%

African pitchblende L-50 October 1944 – November 1944 4% - 6%

Colorado concentrates L-19 November 1944 – January 1946 16% - 18%

African pitchblende R-10 February 1946 – June 1946 2% - 3%

Torbernite Q-20 - ~8.2%

Torbernite Q-20 June 10, 1946 – June 13, 1946 14.4 tons

Residues and scrap N/A June 1943 – June 1946 Varying

Notes:

Source: Reformatted version of attachment included in reference document (ORAU, 1981).

a

Assay of uranium = Assay of U3O8 x 0.842

- Indicates “unknown”

Colorado concentrates were processed about 50% of the time of Linde operation. 

The maximum quantity of ore processed in any week was 1.5 million pounds of R-10. 

Step I processes were terminated July 31, 1946 and Step II processes ended on March 8, 1944 

(Aerospace, 1981). Step III shutdown occurred on June 30, 1949, and Linde Ceramics Plant clean-up 

began sometime before Step III shutdown. Some Step II equipment located in Building 30, including 

processing tanks and process piping, was removed in March and April of 1948 (Kent, 1948b). 

Dismantling of Step I and remaining Step II equipment in Building 30 was apparently completed by 

the end of 1948, and part of the building was released for general use in November, 1949. In general, 

lumber and metal removed as part of the dismantling operations were surveyed for contamination and 

contaminated pieces were shipped offsite for storage (Heatherton, 1949f).

The Linde site was, and continues to be, serviced by a series of underground tunnels that house gas, 

electrical, water, steam, telephone, and other utility lines. Tunnels were a maximum dimension of 

8-10 feet high and 15 feet wide. Each tunnel had exhaust fans (approximately 6 feet in diameter) that 

pulled air through the tunnels (Personal Communication, 2010b; Personal Communication, 2010c; 

Army Corps, 2002). The average air exchange rate within any particular tunnel section was estimated 

by the Atomic Energy Commission (AEC) as approximately one every 10 hours. The tunnels have 

few stairway access points and several locations where covered manways may be used to access the 

tunnel (Army Corps, 2002). These tunnels are routinely inspected and accessed for maintenance 

activities. However, no uranium process piping was ever installed in these tunnels (Army Corps, 

2002). Documentary evidence indicates that the utility tunnel sections near the Ceramics Plant 

(Buildings, 30, 31, 37 and 38) were constructed in 1957 and 1961, which is after the December 31, 

1953 end date of the covered period (Coutts, 2005). There was also a utility tunnel section running 

between Building 14 (the “Tonawanda Laboratory”) and Building 8 (the “Power House”) that was 

assumed to be in existence during the SEC period. 

Uranium ore processing from the 1940s resulted in contamination of Linde site building surfaces, 

soils, building sumps, and sanitary sewer system. In addition, approximately 55 million gallons of 

liquid-waste effluent was injected into seven wells from February 27, 1945 through mid-July 1946. 
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The wells were in two general areas: three wells near Building 8 and four wells in the area associated 

with Buildings 30 and 38. These wells were drilled approximately 150 feet deep and passed through a 

clay formation into a gravel and sand layer and the bedrock layer. Soil could have been contaminated 

by (1) uranium processing going on at the facility, (2) backflow of the injection wells as personnel 

were trying to pump effluent into the wells, and/or (3) clogs in the well/material blowing-out during 

attempts to clean the wells. It has been suggested that water runoff (e.g., from rain or snow melt) 

could have picked up radiological contamination in the soils and flooded the service tunnels 

throughout the lifetime of the Linde site, resulting in a constant contamination level (NIOSH, 2010). 

The utility tunnels would have been routinely accessed by inspectors and maintenance personnel 

throughout the site history. While there is limited information on the number of hours a worker may 

have worked in these tunnels, according to the Army Corps of Engineers 2002 report, Dose 

Assessment for the Existing Surface Contamination Within the Linde Utility Tunnel Complex, 

approximately two months a year are needed for annual maintenance (e.g., sump pump replacement, 

condensate pump repair, lighting repairs) (Army Corps, 2002). This report also provides an estimate 

of the effort required for tunnel inspection each year; this estimate is supported by worker interviews 

(Personal Communication, 2010a; Personal Communication, 2010b; Personal Communication, 

2010c). There were stairwells from the tunnels leading up to Buildings 2, 8 and 14. However, none 

of the records indicate that it was general practice for employees to use the tunnels to get from one 

building to another; such a practice was not condoned by the company (Personal Communication, 

2010c) and was against company policy. 

Shortly after the shutdown of Step III production, a comprehensive clean-up effort was undertaken to 

reduce levels of radioactivity in Building 30 so it could be released to Linde for unrestricted use 

(Heatherton, 1950). After removal of the bulk of the process equipment, the entire building was 

vacuum-cleaned and flushed with water. Afterwards, a systematic radiation survey was conducted to 

identify areas of contamination. Decontamination was accomplished primarily by removing 

contaminated parts of the building (e.g., portions of the second-floor balcony on which process 

operators had been stationed) and by abrading surfaces (mostly by sandblasting, although oxygen 

acetylene torches were also used). In instances where sandblasting was ineffective (i.e., on brick or 

cinder-block walls and rough concrete floors), a pneumatic hammer was used to remove contaminated 

material (Heatherton, 1950). After each area was decontaminated, it was again cleaned and flushed, 

and a final radiation survey was performed. This work was completed by February 28, 1950 (Kent, 

1950a). 

In November 1952, a contamination survey of the Step III processing areas in Building 38 was 

conducted for the purpose of evaluating the release of the work space back to Linde following 

termination of Contract AT-(30-1)-GEN-165 (Harris, 1952). An amendment to the contract, dated 

October 31, 1953, required the decontamination of the Step III process area floors and miscellaneous 

equipment. A February 11, 1954, survey showed that the radiation levels of the floor and some of the 

equipment were still above the specified standards and would need to be either removed or, in the case 

of the floor, covered with asphalt tile (Belmore, 1954). The building was declared suitable for release 

following a subsequent survey performed April 11-15, 1954 (Harris, 1954). 

In 1976, in the earliest stages of the Formerly Utilized Sites Remedial Action Program (FUSRAP), the 

Oak Ridge National Laboratory surveyed the Linde Tonawanda site (ORNL, 1978). This survey, 

conducted from October 18, 1976 through November 5, 1976, included both the Linde Ceramics 
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MED/AEC process buildings and the Tonawanda Lab. The purpose of the survey was to determine if 

remediation would be required. Radiation and radioactive contamination measurements were taken 

inside Buildings 14, 30, 31, 37, and 38, on the property outside of the buildings, and at nearby offsite 

locations. 

The Bechtel 1993 Remedial Investigation Report (Bechtel, 1993) shows that areas of residual 

radioactive contamination were also associated with areas in or near Buildings 57, 58, and 90. The 

highest indoor radiation levels were found in the principal production buildings, Buildings 30 and 38. 

Table 5-3 shows selected events at Linde Ceramics for the period under evaluation. 

Table 5-3: Linde Ceramics Timeline for the Period Under Evaluation

Yeara Event(s)

1947 Step III production resumes.

1948 Steps I and II process equipment dismantling begins.

1949 Step III production ends. Decontamination of Building 30 continues.

1950 Decontamination of Building 30 complete.

1952 Step III dismantlement begins.

1954 AEC contractual work comes to an end with completion of clean-up activities. Building 38 released to Linde.

Note: 

a Dates are identified as specifically as possible based on current information.

5.2 Radiological Exposure Sources from Linde Ceramics Plant Operations

The following subsections provide an overview of the internal and external exposure sources for the 

Linde Ceramics Plant class under evaluation. 

5.2.1 Internal Radiological Exposure Sources from Linde Ceramics Plant Operations

The primary source of internal radiological exposure resulting from Linde Ceramics Plant processing 

operations was inhalation and/or ingestion of uranium dioxide and/or uranium tetrafluoride. For 

non-process workers, the primary source of internal radiological exposure was inhalation and/or 

ingestion of uranium ore contamination re-suspended as a result of daily plant activities as well as

decontamination activities performed during this period. The hazards represented from 

uranium-bearing dust in the air were well-documented, particularly in the years preceding 1948 (Kent, 

1948a). 

The radiological hazard presented by uranium and uranium progeny results primarily from alpha 

particles emitted by U-238 (4.15 MeV and 4.20 MeV) and its isotopes U-235 (4.37 MeV, 4.40 MeV, 

and 4.58 MeV) and U-234 (4.72 MeV and 4.77 MeV). Naturally occurring uranium is 0.71% (w/w) 

U-235 and 0.0055% (w/w) U-234. Linde Ceramics did not receive or process uranium enriched in the 

U-235 isotope; therefore, the uranium oxide and uranium hexafluoride are assumed to contain 

uranium in the same isotopic ratios as natural ore. On an activity basis (i.e., dpm/gram) the U-235 

will be present in negligible amounts at these enrichment levels, but the U-234 activity will be at a 
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level that is essentially equal to U-238 due to its much shorter half-life (2.46E05 years for U-234 and 

4.47E09 years for U-238, respectively). 

Other alpha-emitting radionuclides occur naturally as part of the U-238 decay process. These would 

have been removed during the Step I processing of uranium feed materials for uranium tetrafluoride 

production. Sufficient time would not have elapsed to allow appreciable in-growth of these progeny 

so that an additional hazard would have been posed to Linde personnel. However, continued 

lower-level exposures to uranium progeny and radon can be assumed because some radioactive waste 

was disposed of onsite and initial clean-up was not completed until the end of 1954 (ORAUT-TKBS0025). 

As previously discussed, the utility tunnel sections near the Ceramics Plant (Buildings, 30, 31, 37 and 

38) were constructed in 1957 and 1961, which is after the December 31, 1953 end date of the covered 

period (Coutts, 2005, pdf p. 2). Because of this, there is no source term for underground radon 

exposure in this area of the site during the time period evaluated for this SEC petition. It is known 

that the utility tunnel section running between Building, 10, 11 and 14 (the “Tonawanda Laboratory”) 

and Building 8 (the “Power House”) was in existence during the SEC period. While Building 14 was 

known to have processed ore to produce uranium pigments prior to WWII, such ores were preprocessed Colorado Plateau ores that contained little or no radium (Linde, undated). Unprocessed 

African ores were refined in Building 30 of the ceramics Plant. The Tonawanda Laboratory is known 

to have handled smaller quantities of unprocessed African ores as a pilot program for the production 

facility, particularly in the period from October 11, 1943 through December 15, 1943 (Jenness, 

undated). The documentary evidence is supplemented by 1976 borehole measurement data of soil 

contamination that show radium levels that do not exceed background levels, an indication that 

African ores were not a significant contaminant around Building 14, in contrast to samples taken in 

the area of the Ceramics Plant, which show elevated radium levels in the first few feet of soil in many 

places. 

5.2.2 External Radiological Exposure Sources from Linde Ceramics Plant Operations

Employees could have received external radiation exposures from uranium and uranium progeny. The 

uranium content of mined uranium ores varied based on the assay of the rock being mined. Much of 

the potential for external exposure to workers was due to uranium progeny. 

5.2.2.1 Photon 

External exposures to photon radiation would have resulted from emissions from uranium and 

uranium progeny. Photon exposure during the operation of the Step III process would have been 

primarily limited to the immediate short-lived uranium progeny (Th-234 and Pa-234m). 

5.2.2.2 Beta

Exposure to beta sources for Linde Ceramics Plant employees would have resulted principally from 

uranium decay products. In the uranium-series decay scheme, beginning with U-238, the short-lived 

isotope Pa-234m emits the most energetic beta particle (2.28 MeV). It is this beta particle that 

accounts for the shallow-dose hazard associated with handling uranium and uranium tetrafluoride. 
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5.2.2.3 Neutron 

There was a small potential for personnel neutron exposures from the uranium operations at Linde 

Ceramics. As described in Section 5.2.1, site personnel received and handled uranium tetrafluoride. 

Low-atomic-number elements such as fluorine emit neutrons with an average energy of about 1.5 

MeV when struck by alpha particles (referred to as alpha-neutron [“α-n”] reactions). The intensity of 

the radiation field from these reactions increases as a function of the enrichment. Because only 

uranium with a natural isotopic ratio (“natural enrichment”) was used at Linde, the radiation field was 

significantly lower than for the beta or gamma components, and as such, neutron radiation is not 

considered a significant exposure concern. 

6.0 Summary of Available Monitoring Data for the Class Evaluated 

by NIOSH

ATTRIBUTION: Section 6.0 and its related subsections were completed by Jason Davis, Oak Ridge 

Associated Universities. The rationales for all conclusions in this document are explained in the 

associated text. 

The following subsections provide an overview of the state of the available internal and external 

monitoring data for the Linde Ceramics Plant class under evaluation.

6.1 Available Linde Ceramics Plant Internal Monitoring Data

Documents suggest that tentative arrangements had been made for uranium urinalysis of certain 

groups of Linde employees as early as 1944 (Ferry, 1944); however, no records are available to 

indicate that these early analyses were performed. A page titled, “Schedule of Examinations, Contract 

AT-30-1-GEN-165,” which was scheduled to begin in 1947, indicates that 60 cm3 of urine from each

employee was to be sent monthly to the University of Rochester for analysis (Rennich, 1947). Preemployment urine sample results are available for 75 different workers. An additional 566 sample 

results are available for 113 employees, covering the time period from 1948 through January 1950 

(AEC, 1947-1950a; AEC, 1947-1950b; AEC 1951; Harris, 1952). All sample result data are

identified by name and some results are additionally identified by job title. Limited uranium 

urinalysis data have been identified for Linde workers after the cessation of Step III operations 

(fluorination of uranium dioxide to uranium tetrafluoride). A summary of the available bioassay 

records by year is provided in Table 6-1. 

Table 6-1: Number of Available Linde 

Bioassay Records Per Year

Year # of Samples

1947 75

1948 372

1949 183

1950 11

Uranium fusion photofluorimetry urinalysis was performed initially by the University of Rochester 

and later by the AEC New York Operations Office (Wolf, 1948). The recorded results of Linde 
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uranium urinalysis during Step III production ranged from 0 to 3.10 mg/L, with many of the higher 

results reported in the November to December 1947 samples collected as “pre-employment urines.” 

Because preparation activities for the resumption of Step III production occurred before collection of 

these samples, it is possible that the elevated urinalysis results represented exposures received either 

during rehabilitation of the Step III equipment or from exposures to less-soluble uranium during 

earlier operations. 

NIOSH has access to breathing zone data, general air sampling data, and contamination surveys that 

establish source term information for onsite uranium and uranium progeny during the operational 

period (AEC, 1947-1951; AEC, 1954b; Harris, 1952; Heatherton, 1948e, f; Heatherton, 1949c, d, e; 

Klevin, 1948; Klevin, 1949). A summary of the individual air sampling data are presented in Table 6-

2. As discussed, NIOSH also has data from radiological surveys conducted during Step III operations 

and during the decontamination of the Linde facilities that followed the cessation of operations and 

removal of source term materials (Harris, 1952; Harris, 1954; Klevin, 1954a; Weinstein, 1954). In 

addition, NIOSH has access to dust samples (AEC, 1954a), contamination smear samples (AEC, 

1954b), and post-remedial action data (Harris, 1952; Heatherton, 1950; Klevin, 1954a) documenting 

site contamination for the period under evaluation in this report. 

Table 6-2: Number of Available Air 

Monitoring Records Per Year

Year # of Samples

General Air Breathing Zone

1947 6 0

1948 57 50

1949 150 109

1950 37 19

Details regarding the various analyses used and the associated minimum detectable activities are 

presented in the Technical Basis Document An Exposure Matrix for the Linde Ceramics Plant 

(including Tonawanda Laboratory) (ORAUT-TKBS-0025). 

6.2 Available Linde Ceramics Plant External Monitoring Data

For part of the period from 1947 to 1949, weekly film badge measurements of beta and gamma 

exposure were available in the form of a database printout (Film Badge Dataset, 1948-1949). The 

printout data have been de-identified by removal of personnel names (Wallace, 2003), but many of the 

records are labeled with a job title. The data file contains about 6,000 records from January 7, 1948 

through December 12, 1949. By comparison with a copy of a laboratory film badge report (AEC, 

1949), it was determined that the listed date specifies the beginning of the week the film badge was 

worn. 

Supplementing this database printout, NIOSH has access to two weekly film badge reports covering 

the weeks of March 28, 1949 and April 4, 1949 (Ceramics Film Badge Report, 1949). These reports 

list individual badge numbers and are identified by name and social security number. In addition, 

NIOSH has access to summary film badge reports which list the total number of film badges issued as 
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well as the exposure ranges for the covered time period (AEC, 1949; Hayden, 1948; Heatherton, 1947; 

Heatherton, 1948a, b, c, d; Kent, 1947; Kent, 1949b). 

No personnel external dosimetry data have been identified for Linde Ceramics workers prior to the 

start or after the cessation of Step III operations. However, NIOSH does have access to radiological 

dose rate and contamination data documenting site contamination for the period under evaluation in 

this report (AEC, 1954a; AEC, 1954b; Harris, 1952; Heatherton, 1950; Klevin, 1954a). 

Details regarding the various analyses used and the associated minimum detectable activities are 

presented in the Technical Basis Document An Exposure Matrix for the Linde Ceramics Plant 

(including Tonawanda Laboratory) (ORAUT-TKBS-0025). 

6.3 Available Linde Ceramics Plant Utility Tunnel External Monitoring Data

Limited radiological characterizations of the utility tunnels were conducted during the 1976 and 1981 

Formerly Utilized Sites Remedial Action Program (FUSRAP) surveys of the Linde site (ORNL, 1978; 

Bechtel, 1982). A detailed characterization of these tunnels was performed in the summer of 2001 

(Army Corps, 2002). During the remedial investigation (Bechtel, 1993, Section 4), data were 

collected to determine the nature and extent of subsurface contamination. Borehole samples were 

analyzed, including borehole B29R23, located just northwest of Building 30 near a former injection 

well found just inside the building. This borehole was sampled at three intervals and showed 

low-level Ra-226 concentration in the first interval (Bechtel, 1993, Section 4-25), possibly as a result 

of spilled effluent at the injection well site. The concentration decreased at the deeper sample interval.

The detailed radiological characterization performed in 2001 (Army Corps, 2002) was based on beta 

surface contamination levels. Six to eight circumferential measurements were taken in one-meter 

increments along the tunnel. In addition, hot spot readings were collected. The maximum result was 

recorded. The beta contamination levels were then converted to individual isotopic activities based on 

gamma spectroscopy analysis of soil samples taken during site remediation. The associated data 

analysis performed by the Army Corps of Engineers is presented in Table 6-3 below (Army Corps, 

2002). 

Table 6-3: Radionuclide Fraction Calculation Using Average Linde Soil Concentrations

Isotope

Soil Concentration 

Gamma Spec 

(pCi/gm)

Uranium 

Fraction

F(U)

Soil Concentration 

Isotopic

(pCi/gm)

Source 

Fraction

(fS)

Beta 

Emission

(β/dis)

Beta 

Fraction

(fβ) 

Isotopic 

Abundance 

per Beta 

(SA)

Ra-226 7.46 - 7.46 0.080 1.82 0.170 0.094

Th-230 8.49 - 8.49 0.092 - - 0.107

U-238 36.33 0.473 36.33 0.392 1.98 0.830 0.419

U-235 - 0.022 1.69 0.018 - - 0.020

U-234 - 0.505 38.79 0.418 - - 0.447

Total - - 92.76 1.000 3.80 - -

Source: Table 2.1 from Dose Assessment for the Existing Surface Contamination Within the Linde Utility Tunnel Complex

(Army Corps, 2002).
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7.0 Feasibility of Dose Reconstruction for the Class Evaluated by 

NIOSH

The feasibility determination for the class of employees under evaluation in this report is governed by 

both EEOICPA and 42 C.F.R. § 83.13(c)(1). Under that Act and rule, NIOSH must establish whether 

or not it has access to sufficient information either to estimate the maximum radiation dose for every 

type of cancer for which radiation doses are reconstructed that could have been incurred under 

plausible circumstances by any member of the class, or to estimate the radiation doses to members of 

the class more precisely than a maximum dose estimate. If NIOSH has access to sufficient 

information for either case, NIOSH would then determine that it would be feasible to conduct dose 

reconstructions. 

In determining feasibility, NIOSH begins by evaluating whether current or completed NIOSH dose 

reconstructions demonstrate the feasibility of estimating with sufficient accuracy the potential 

radiation exposures of the class. If the conclusion is one of infeasibility, NIOSH systematically 

evaluates the sufficiency of different types of monitoring data, process and source or source term data, 

which together or individually might ensure that NIOSH can estimate either the maximum doses that 

members of the class might have incurred, or more precise quantities that reflect the variability of 

exposures experienced by groups or individual members of the class as summarized in Section 7.6. 

This approach is discussed in DCAS’s SEC Petition Evaluation Internal Procedures which are

available at http://www.cdc.gov/niosh/ocas. The next four major subsections of this Evaluation 

Report examine:

• The sufficiency and reliability of the available data. (Section 7.1) 

• The feasibility of reconstructing internal radiation doses. (Section 7.2) 

• The feasibility of reconstructing external radiation doses. (Section 7.3) 

• The bases for petition SEC-00154 as submitted by the petitioner. (Section 7.4) 

7.1 Pedigree of Linde Ceramics Plant Data

This subsection answers questions that need to be asked before performing a feasibility evaluation. 

Data Pedigree addresses the background, history, and origin of the data. It requires looking at site 

methodologies that may have changed over time; primary versus secondary data sources and whether 

they match; and whether data are internally consistent. All these issues form the bedrock of the 

researcher’s confidence and later conclusions about the data’s quality, credibility, reliability, 

representativeness, and sufficiency for determining the feasibility of dose reconstruction. The 

feasibility evaluation presupposes that data pedigree issues have been settled.
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7.1.1 Internal Monitoring Data Pedigree Review

ATTRIBUTION: Section 7.1.1 was completed by Jason Davis, Oak Ridge Associated Universities. 

The rationales for all conclusions in this document are explained in the associated text. 

NIOSH located limited bioassay monitoring data for the period prior to the start and after the 

termination of Step III production. Therefore, an internal monitoring data sufficiency and pedigree 

evaluation is not possible for the internal monitoring data outside the 1947-1949 time period. 

Similarly, NIOSH did not locate any radon monitoring data for the period under evaluation; therefore, 

a data sufficiency and pedigree evaluation is not possible for radon monitoring data during the 

1947-1953 time period. 

Urinalysis data associated with Step III productions are contained in original typed reports and typed 

and handwritten sample data log sheets; these are legible primary data sources. As mentioned in 

Section 6.1, all of the data available are identified by employee name and, in some cases, by specific 

job title. Out of the 43 employees explicitly identified as Step III process workers, NIOSH has 

urinalysis data for 41 employees. 

Similarly, the air sampling and survey data associated with the decontamination and decommissioning 

activities of the 1949-1953 time period are contained in original typed summary reports and 

handwritten and typed sample log sheets; these are therefore considered primary data sources. The 

available general air sampling data contain notes pointing to specific locations within the processing 

areas. Available breathing zone air sampling data contain notes that describe tasks being performed 

during sampling and, in some cases, the job titles of those individuals carrying out those tasks. 

7.1.2 External Monitoring Data Pedigree Review

ATTRIBUTION: Section 7.1.2 was completed by Jason Davis, Oak Ridge Associated Universities. 

The rationales for all conclusions in this document are explained in the associated text. 

NIOSH did not locate any external personnel monitoring data for the period following the termination 

of Step III production. Therefore, an external monitoring data sufficiency and pedigree evaluation is 

not possible for these data outside the 1947-1949 time period. As described in Section 6.2, NIOSH 

has access to a database printout of approximately 6,000 weekly film badge results for the Step III 

operations/production period. The printout contains beta and gamma measurements; neutron 

monitoring was not performed during this time period. The data in this printout have been deidentified by removal of personnel names, preventing direct correlation between the records and 

individual workers. However, the data are identified by job title, allowing for the correlation of the 

highest recorded doses with specific categories of workers. NIOSH compared these data with the only 

available original laboratory film badge report and confirmed that the dates on the printout specify the 

beginning of the week the film badge was worn (AEC, 1949). As the materials handled and the 

methods used did not change during the covered operational period, these data may be used to 

estimate external radiation exposure for all workers for this time period. NIOSH intends to use this 

information and exposure data to support its ability to bound external dose for the class under 

evaluation. 
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7.2 Evaluation of Bounding Internal Radiation Doses at Linde Ceramics Plant

ATTRIBUTION: Section 7.2 and its related subsections were completed by Jason Davis, Oak Ridge 

Associated Universities, and Mutty Sharfi, MJW Corporation. The rationales for all conclusions in 

this document are explained in the associated text. 

The principal sources of internal radiation doses for members of the class under evaluation were: (1)

the inhalation of uranium-bearing dust during the conversion of uranium dioxide into uranium 

tetrafluoride from 1947-1949; and (2) the potential inhalation or ingestion of residual contamination in 

the uranium processing buildings (i.e., Buildings 14, 30, 31, 37, and 38) during dismantling and 

decontamination activities from 1947-1953 (Bechtel, 1993; ORAUT-TKBS-0025). The following 

subsections address the ability to bound internal doses, methods for bounding doses, and the 

feasibility of internal dose reconstruction. 

7.2.1 Evaluation of Bounding Process-Related Internal Doses

The following subsections summarize the extent and limitations of information available for 

reconstructing the process-related internal doses of members of the class under evaluation. 

7.2.1.1 Urinalysis Information and Available Data 

As discussed in Section 6.1, individual uranium urinalysis data from November 1947 to 1950 are 

available for 41 out of 43 workers identified as Step III process workers (Sample Log Sheets, 1947-

1961; Logbook, 1947-1949; AEC, 1947-1950a; AEC, 1947-1950b; AEC, 1951; Klevin, 1948; Klevin, 

1949). This period covers Step III production in Building 38. Additionally, individual uranium 

urinalysis data are available for 70 workers that cannot be positively identified as Step III process 

workers (Sample Log Sheets, 1947-1961; Logbook, 1947-1949; AEC, 1947-1950a; AEC, 1947-

1950b; AEC, 1951). However, no employee roster has been located to confirm what percentage of the 

total worker population is represented in the urinalysis data. After completion of step III production 

activities in 1950, bioassay samples are not available. Thus between 1950 and 1953, NIOSH does not 

have access to any monitoring data for workers who may have participated in work activities, 

including potential decontamination and dismantling operations within Building 38. 

During 1948, a subcontractor, H. K. Ferguson, undertook extensive dismantling activities for the Step 

I and Step II equipment in Building 30 (Kent, 1948c). The Step I equipment, in particular, was used 

for processing domestic (pre-processed) and African ores, with their full complement of uranium 

progeny. While the documentation shows that the Ferguson employees were monitored, no such 

monitoring records have been found. Further, because the equipment used for the Step I refining 

process may have been contaminated with raffinates containing heightened concentrations of uranium 

progeny, NIOSH has determined that there is insufficient data to bound the internal dose such 

employees may have received during the dismantling of this equipment. In addition, although the 

Linde employees working in the Step III processing at Building 38 were monitored for uranium 

intakes, it is not possible to determine which Linde personnel might have also been exposed to the 

elevated levels of uranium progeny contamination in Building 30 during the SEC period. 

The shipping and receiving area of Building 30 was decontaminated and released for private use on 

November 28, 1949, three months before the entire building was fully decontaminated (Kent, 1949c). 
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Since no radioactive spectrum data were available until the 1976 FUSRAP survey, NIOSH finds that 

it is not possible to bound the internal dose for all Linde employees for the SEC period. 

Since raffinates containing heightened, and unmeasured, concentrations of uranium progeny were 

produced in Building 30, the internal exposures during the 1949 and 1950 decontamination activities, 

as well as the residual radioactivity in that building between March 1, 1950 and December 31, 1953 

cannot be bounded for that period. In addition, the nature of the activities carried out in Building 30 

for the above period cannot be determined so exposure to resuspended radioactive contamination, 

containing unknown levels of radioactive progeny, could have occurred, if renovation work took place 

during the period. 

7.2.1.2 Airborne Levels

NIOSH has been able to locate air sample data providing gross alpha analytical results for the Step III 

operational period. These data are in the form of sample log sheets (AEC, 1947-1951; Heatherton, 

1948j; Sample Log Sheets, 1947-1961), weekly progress reports that present sampling data 

(Heatherton, 1947; Heatherton, 1949a, b, c, d, e; Kent, 1949a,), and two prepared reports that detail 

the dust hazards present during Step III operations (Klevin, 1948; Klevin, 1949). These last two 

reports detail the general area samples taken as well as breathing zone samples for different stages in 

the processing operation. Data are presented for each of four job groups involved in the Step III 

operations, including foremen and operator groups A-C. Within these job groups, the Progress Report 

for week ending March 27, 1949, provides individual job titles (Kent, 1949a). The final page of each 

Progress Report for the weeks ending in March 27, 1949 and July 24, 1949, includes a list of 

employees who worked in the Step III operations area (Kent, 1949a; Kent, 1949b). 

Heatherton describes various methods for decontaminating hard surfaces at the Linde Ceramics Plant 

in Building 30 (Heatherton, 1950). Included in Table V of Heatherton’s survey is a data summary 

showing the minimum, maximum, and average air concentrations measured during the evaluation of 

different decontamination options. Thirty-eight air dust samples were collected while vacuumcleaning rafters covered with radioactive dust, while sandblasting, and while using the oxygen blow 

pipe (Heatherton, 1950). NIOSH has access to the original sample data logs that provide not only the 

air sample results but also the processes being carried out while sampling was conducted (AEC, 1947-

1951). 

Another decontamination option was the removal of contaminated concrete brick and cinder-block 

with a pneumatic hammer. In order to estimate the radioactivity hazards in performing this work, dust 

samples were taken and analyzed for alpha activity. The alpha activity data present values in terms of 

exposure in MACs, where one MAC = 70 dpm/meter3

 alpha. Eighteen dust samples were collected in 

the general area of the operation and in the breathing zone (Heatherton, 1950). 

Dust samples were also collected in the general area during the decontamination of the Step III 

processing area (AEC, 1954b). A memo written at this time points out that the dust concentrations 

observed during this decontamination effort are lower than those observed during the Step I and Step 

II decontamination efforts (Klevin, 1954b). 

Waste materials (raffinates) were transported offsite (to LOOW and/or Ashland) prior to the end of 

operations (Aerospace Corporation, 1981; Argonne, 1987; Anderson, 1945; Malone, 1956; Robinson, 
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1945; Robinson, 1973; Thornton, 1976). Although workers outside the operational period would have 

had minimal exposure potential to this material in its concentrated form, the workers who dismantled 

the Step I equipment in 1948 and any Linde workers who may have assisted in this operation or 

worked in Building 30 during the SEC period, may have been exposed to raffinates with unknown 

concentrations of radioactive progeny. 

To determine the exposure potential from residual surface contamination on the site, a review of 

available isotopic data was conducted. Isotopic data from FUSRAP studies, including Building 30 air 

samples (ORNL, 1978), sanitary sewers (Bechtel, 1982), and other surveys of soils and sediments on 

site are summarized in Attachment One of this evaluation report and were used to estimate exposure 

from uranium progeny for the period after 1969. 

NIOSH believes that the available air sample and bioassay data, and the methodology in ORAUTTKBS-0025, are not, however, sufficient to support bounding internal dose estimates for unmonitored 

workers in the class under evaluation with sufficient accuracy. NIOSH concludes that it cannot 

establish a bounding internal dose estimate from airborne particulates containing the isotopes of 

uranium (i.e., U-238, U-234, and U-235). As mentioned in Section 5.2, exposure to radon and other 

uranium progeny are not believed to be a significant source of internal exposure due to the age of the 

source and product materials, and the fact that the processing residues were shipped offsite for 

storage. However, continued lower-level exposures to uranium progeny and radon can be assumed 

because some radioactive waste was disposed of onsite and initial clean-up was carried out in stages 

and was not completed until 1954 (Harris, 1954; ORAUT-TKBS-0025). 

7.2.2 Evaluation of Bounding Ambient Environmental Internal Doses

Ambient environmental internal doses could have resulted from the inhalation of radionuclides in 

locations outside of the Linde Ceramics process/operations areas. NIOSH has identified no specific 

indication that ambient air particulate levels were monitored at Linde Ceramics. Based on this 

information and the available data and documentation associated with Linde operations, NIOSH has 

concluded that ambient environmental internal doses associated with ambient environmental airborne 

exposures outside of the process areas cannot be accounted for, and cannot be bounded by application 

of operational internal dose assessment methods. Therefore, further analysis and evaluation of the 

ability to bound (reconstruct dose with sufficient accuracy) ambient environmental internal dose is not 

included in this report. 

7.2.3 Methods for Bounding Internal Dose at Linde Ceramics Plant

NIOSH intends to use the available bioassay data whenever data for an individual is available to 

reconstruct dose for employees with non-scheduled cancers during the SEC period. 

7.2.3.1 Methods for Bounding Internal Dose for Site Workers 

NIOSH finds that internal dose from exposure to uranium and uranium progeny cannot be bounded 

for Linde workers during the SEC period. Both H. K. Ferguson employees and Linde employees were 

involved in the dismantling of equipment and building contamination process for the period from 

1948 through February 28, 1950 in Building 30. As previously explained, NIOSH finds that the 

presence of raffinate contamination on equipment and building surfaces makes it infeasible to bound 
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the internal dose from uranium and uranium progeny. Furthermore, Building 38, containing the Step 

III equipment, was not finally decontaminated to an acceptable level until April, 1954. Although 

Building 38 was thought not to have been contaminated by heightened levels of uranium progeny, the 

decontamination workers have not been identified, and dosimetry data have not been found for any 

workers after February, 1950. There is no evidence that demonstrates any access control to any of the 

Linde Ceramics Plant buildings from 1950 through 1953, which, along with a complete absence of 

bioassay and air monitoring data during a period when decontamination activities were ongoing, has 

led NIOSH to conclude that reconstructing internal dose is not feasible for any Linde worker during 

the period from November 1, 1947 through December 31, 1953. 

7.2.3.2 Methods for Bounding Internal Radon Dose for Site Workers 

During Ceramics Plant production, the only source of radon was African ore processing. No direct 

radon measurements during the period of Step III operations are available. An estimate was made 

based on the lowest measured indoor concentrations at the Linde site during African ore processing. 

Approximately 20% of the measurements in the Linde ore-processing building yielded results of 10 

pCi/L or less, with most of these results at or near 10 pCi/L. Therefore, 10 pCi/L was assumed to be 

outdoor air concentration. After the end of African ore processing, radon concentration in the main 

ore-processing building (Building 30) and all other Linde Ceramics Plant buildings was assumed to 

remain at the 10-pCi/L level due to the removal of uranium ores and their raffinates. Concentrations 

in other Linde buildings were also assumed to be 10 pCi/L until the end of clean-up in those buildings. 

Because the locations of many workers are likely to be unknown, it was assumed that all workers were 

exposed to 10 pCi/L of radon from November 1, 1947, through December 31, 1953. As mentioned in 

Section 5.2, exposure to radon and other uranium progeny are not believed to be a significant source 

of internal exposure due to the age of the source and product materials, and the fact that the processing 

residues were shipped offsite for storage. Because there is a lack of source material to increase the 

radon concentration during the evaluated period, the assumption of a 10 pCi/L radon concentration 

represents a sufficiently accurate estimate for the purposes of bounding internal exposures for the 

class under evaluation. 

As discussed in Section 5.2.1, there is no evidence of an increased radium source-term for soils near 

the utility tunnel section running between Building 14 (the “Tonawanda Laboratory”) and Building 8 

(the “Power House”), which was assumed to be in existence during the SEC period. Therefore, 

NIOSH believes that a 10 pCi/L radon level that has been established for surface buildings in the 

Ceramics Plant will be bounding for these worker exposures during the SEC-00154 petition period. 

7.2.4 Internal Dose Reconstruction Feasibility Conclusion 

NIOSH has concluded that there is insufficient internal monitoring data, air monitoring data, and area 

survey data to support bounding internal exposures for uranium and uranium progeny (excluding 

radon) during the period from November 1, 1947 through December 31, 1953. Radioactive operations 

terminated in 1949 and source-term materials were removed from the site. The application of the 

survey and air monitoring data as outlined in ORAUT-TKBS-0025, therefore, will not result in 

conservative estimates of exposure for the Linde Ceramics activities conducted during the period 

under evaluation (November 1, 1947 through December 31, 1953). 
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7.3 Evaluation of Bounding External Radiation Doses at Linde Ceramics Plant

ATTRIBUTION: Section 7.3 and its related subsections were completed by Joseph Guido and Mutty 

Sharfi, MJW Corporation, and Jason Davis, Oak Ridge Associated Universities. The rationales for 

all conclusions in this document are explained in the associated text. 

The principal sources of external radiation doses for members of the evaluated class were: (1) direct 

beta/gamma exposure from uranium and uranium progeny contained in Step III process materials 

(uranium oxide and uranium tetrafluoride compounds); and (2) residual contamination present on 

building surfaces and inside equipment and components resulting from Step III and all other site 

operations. 

The following subsections address the ability to bound external doses, methods for bounding doses, 

and the feasibility of external dose reconstruction. 

7.3.1 Evaluation of Bounding Process-Related External Doses

The following subsections summarize the extent and limitations of information available for 

reconstructing the process-related external doses of members of the class under evaluation.

7.3.1.1 Personnel Dosimetry Data

As described in Section 6.2, NIOSH has access to a database printout of approximately 6,000 weekly 

film badge results (Film Badge Dataset, 1948-1949). These data have been de-identified by removal 

of personnel names, thus preventing direct correlation between the respective dose records and 

individual workers. The tables do, however, provide a correlation between personnel job 

classifications and the measured doses. 

The computer file had three columns of data. The third data column was obviously the total radiation 

dose. By comparison with a laboratory film badge report (AEC, 1949), the first data column was 

determined to be beta radiation and the second was determined to be gamma radiation. The report 

states both the beta and gamma units to be “exposure, mr.” Progress reports by the Linde health 

physicist refer to the film badge results sometimes as “mr” and sometimes as “mrep” (Heatherton 

1949d, e), but these are essentially equivalent. The beta units are designated in ORAUT-TKBS-0025 

as mrem and are assumed for purposes of dose reconstruction to be equivalent to shallow dose at 0.07 

mm. ORAUT-TKBS-0025 further assumes that gamma radiation units were equivalent to 

milliroentgen. In all cases, results reported as “0”, “*”, or “**” are interpreted as meaning “less than 

the limit of detection” (LOD). Before March 15, 1948, a beta value below the limit of detection was 

reported as "<80." After March 15, 1948, the limit of beta detection was not explicitly stated, but it 

was deduced to be 35 mrem from an examination of the data (ORAUT-TKBS-0025). For records 

before March 15, 1948, a gamma value below the limit of detection (LOD) was reported as "0" or 

"<50." For records after March 15, 1948, the limit of gamma detection was not explicitly stated but 

was deduced to be 45 mR from an examination of the data (ORAUT-TKBS-0025). 

Sufficient job category and workgroup information is contained within the external dosimetry 

database described above to allow for the statistical analysis of the data by job activity and also by 
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work area. This information supports the bounding of external doses for individual occupational 

groups. Such an analysis is presented in ORAUT-TKBS-0025. 

7.3.1.2 Alternative Data Sources for Bounding External Dose

Results of radiation surveys performed at the end of the operational period (Blatz, 1949; Heatherton, 

1950; Wolf, 1949) can be used along with the results of the initial FUSRAP site surveys (ORNL, 

1978) to establish bounding external radiation levels within Linde buildings during standby periods 

and for outdoor areas. The rationale (presented in ORAUT-TKBS-0025) is that survey data from 

Building 30 prior to decontamination would provide a bounding estimate of radiation levels for other 

site buildings and for outdoor areas based on the fact that Building 30 was the most contaminated 

building on the Linde site, as determined at the time of the 1976 FUSRAP survey. Detailed analysis, 

presented in ORAUT-TKBS-0025, uses more limited surveys in 1949 (performed prior to vacuuming 

and flushing of the building) to establish a scaling factor (determined to be 3) for adjusting the 1950 

survey data (Heatherton, 1950) to account for the fact that the measurements taken during the more 

comprehensive 1950 survey occurred after the facility vacuum-and-flushing operation. 

An estimate of neutron exposure during operations involving fluorine is also presented in ORAUTTKBS-0025. This estimate is based on activities specific to Linde and makes use of information on 

neutron radiation generated from alpha radiation documented in ORAUT-OTIB-0024. 

7.3.2 Evaluation of Bounding Ambient Environmental External Doses

Ambient environmental external doses could have resulted from low-level exposures to radioactive 

materials in locations outside of the process/operations areas at Linde Ceramics. There is no specific 

indication that ambient radiation levels were monitored at the Linde site. However, the ambient 

environmental exposures would be included and accounted for in the occupational monitoring data 

available for site personnel. In addition, this site managed only a single radioactive source (natural 

abundance uranium) and had no operations involving other radioactive materials prior to the evaluated 

period. Based on this information and the available data and documentation associated with Linde 

Ceramics Plant operations, NIOSH has concluded that ambient environmental external doses 

associated with exposures outside the direct vicinity of Linde process areas are accounted for and can 

be bounded by application of operational external dose assessment methods. Therefore, further 

analysis and evaluation of the ability to bound (reconstruct dose with sufficient accuracy) ambient 

environmental external dose is not included in this report. 

7.3.3 Linde Ceramics Plant Occupational X-Ray Examinations 

ORAUT-TKBS-0025 provides detailed information on the nature and extent of the occupational 

medical X-ray examination program in place at Linde during the period under evaluation. In 

summary, annual and termination 14 x 17 inch chest X-rays were provided for all plant employees. 

Additionally, pelvic X-ray examinations were also provided to personnel starting in November or 

December 1947 (ORAUT-TKBS-0025) and two additional pelvic X-ray examinations were conducted 

at termination. Recently found evidence establishes that X-rays of Linde workers were taken offsite, 

at the Black Rock Clinic, from 1943 through 1949, which means that no X-ray dose will be given to 

Linde workers for those years.
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7.3.4 Methods for Bounding External Dose at Linde Ceramics Plant

There is an established protocol for assessing external exposure when performing dose reconstructions 

(these protocol steps are discussed in the following subsections): 

• Photon Dose 

• Beta Dose

• Neutron Dose 

• Medical X-ray Dose

Linde Ceramics Site Worker Photon and Beta Dose

External monitoring data summarized in Section 7.3.1.1 can be used as the basis to bound external 

photon and beta exposure for Linde site workers. Adjustments to these data to account for specific job 

categories and work areas can be made based on job description and category information that is also 

contained within the dataset. Adjustments for what are termed “high-” and “low-” risk employees are 

provided in ORAUT-TKBS-0025; however, additional adjustments can be made using the available 

dataset, as appropriate, based on individual claim dynamics. Additional adjustments that have been 

incorporated into the analysis documented in ORAUT-TKBS-0025 include consideration of missed 

dose and ambient environmental dose. 

Bounding estimates of photon and beta dose during periods when operations were not ongoing (i.e., 

during standby periods, and at the Tonawanda Laboratory Facility) can be made using the analysis of 

building radiation levels documented in ORAUT-TKBS-0025. ORAUT-TKBS-0025 divides the 

workers during the period following Step III operations into three classes: 

• Clean-up Worker: Worker who was directly engaged in the removal of radioactive equipment, 

components, or contamination for a substantial portion of the workday. 

• Clean-up Support Worker: Worker who spent a substantial portion of the workday in the building 

or area being decontaminated to support the cleanup activities, but was not actively engaged in the 

removal activities.

• Non Clean-up Worker: All other workers. 

Table 4-24 of ORAUT-TKBS-0025 lists the dose rates for each of worker class, for each year 

following the cessation of Step III processing. 

Neutron Dose 

As noted in Section 5.2.2.3, based on the source material present during the period under evaluation, 

neutrons are not expected to be a significant source of exposure requiring dose reconstruction. As 

individual cases warrant, bounding estimates of neutron exposure may be performed using the 

analysis of potential neutron radiation levels contained in ORAUT-TKBS-0025. 

Medical X-ray Dose
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The bounding approach for reconstruction of medical X-ray dose is defined in the complex-wide 

Technical Information Bulletin, Dose Reconstruction from Occupationally Related Diagnostic X-Ray 

Procedures (ORAUT-OTIB-0006), using the site-specific parameters presented in ORAUT-TKBS0025, as summarized above in Section 7.3.3. As stated above, recently found evidence establishes 

that X-rays of Linde workers were taken offsite, at the Black Rock Clinic, from 1943 through 1949, 

which means that no X-ray dose will be given to Linde workers for those years. 

7.3.5 External Dose Reconstruction Feasibility Conclusion

Based on the available external monitoring data and area radiation survey data, and the information in 

ORAUT-TKBS-0025, NIOSH has the necessary data to support bounding external exposures for 

uranium and uranium progeny during the period from November 1, 1947 through December 31, 1953. 

Application of the methodology in ORAUT-TKBS-0025 supports NIOSH’s ability to bound dose for 

the Linde Ceramics Plant worker class under evaluation during the period from November 1, 1947 

through December 31, 1953. 

7.4 Evaluation of Petition Basis for SEC-00154

ATTRIBUTION: Section 7.4 and its related subsections were completed by Jason Davis, Oak Ridge 

Associated Universities. The rationales for all conclusions in this document are explained in the 

associated text. 

The following subsections evaluate the assertions made on behalf of petition SEC-00154 for the Linde 

Ceramics Plant.

7.4.1 Lack of Individual Monitoring 

SEC-00154: The petitioner asserted that Linde Ceramics Plant workers were not monitored for 

radiation exposure.

NIOSH has located external dosimetry data for the time period from 1947 through 1949 and internal 

dosimetry data for the time period from 1947 through 1950. Linde Ceramics Plant workers employed 

after the cessation of Step III operations were not radiation workers. A radiation worker was an 

employee who had received specific training and qualifications allowing the worker to have 

unescorted access into the controlled area and to perform work of a radiological nature. 

Following the cessation of Step III uranium processing, personnel dosimetry was only required for 

those employees who would be spending more than four hours a week in an area with known 

contamination (Kent, 1948b). In retrospect, in light of available information regarding the 

contamination and possible exposure pathways at the Linde site, NIOSH determined that an 

evaluation of the data available to support dose reconstruction was warranted; consequently, NIOSH 

pursued the evaluation of the petitioner-proposed class presented in this report. 

7.4.2 Adequacy of Data 

SEC-00154: The petitioner asserted that the draft Assessment of the Disposition of SC&A’s Linde Site 

Profile Review Issues in Response to SEC Petitioner Concerns documented limitations of existing 
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records that might prevent the completion of dose reconstructions for members of the proposed class 

(SC&A, 2009). 

Response: SC&A’s Draft Review of the NIOSH Site Profile for the Linde Ceramics Plant and 

Tonawanda Laboratory, Tonawanda, New York (SC&A, 2006) noted the need for clarification within 

the Linde Ceramics Site Profile, and offered suggestions for improving the accuracy of dose 

reconstruction for former Linde workers. The draft report did not document any specific limitations 

of the DOE records that would imply any infeasibility of dose reconstruction for any member of the 

petitioner-proposed class. The limitations, as documented in the report, have been addressed to the 

satisfaction of the Advisory Board on Radiation and Worker Health, as outlined in Table 4 of the draft 

SC&A report (SC&A, 2009).

7.5 Other Potential SEC Issues Relevant to the Petition Identified During the 

Evaluation

ATTRIBUTION: Section 7.5 was completed by Jason Davis, Oak Ridge Associated Universities. The 

rationales for all conclusions in this document are explained in the associated text. 

During the feasibility evaluation for SEC-00154, a number of issues were identified that needed 

further analysis and resolution. The issues and their current status are: 

• ISSUE: During the initial review of the petition and supporting information, ORAUT/DCAS 

raised the issue of whether radon monitoring records exist for the time period under evaluation. 

RESPONSE: NIOSH has been unable to find radon monitoring records for the time period from 

November 1947 through December 1953. However, ORAUT-TKBS-0025 presents a method for 

estimating radon exposures to Linde Ceramics workers for this time period. A summary of this 

method is presented in Section 7.2.3. 

• ISSUE: During an interview with NIOSH, a former worker indicated that the utility tunnels 

running beneath the Linde Ceramics Plant may have been contaminated and may have presented 

an exposure potential for certain workers. 

RESPONSE: Documentary evidence indicates that the utility tunnel sections near the Ceramics 

Plant (Buildings, 30, 31, 37 and 38) were constructed in 1957 and 1961, which is after the 

December 31, 1953 end date of the covered period (Coutts, 2005). Because of this, there is no 

source term for underground radon exposure in this area of the site during the time period 

evaluated for this SEC petition. The utility tunnel section running between Building 14 (the 

“Tonawanda Laboratory”) and Building 8 (the “Power House”) was in existence during the SEC 

period. While Building 14 was known to have processed ore to produce uranium pigments prior 

to WWII, such ores were pre-processed Colorado Plateau ores that contained little or no radium 

(Linde, undated). Unprocessed African ores were refined in Building 30 of the ceramics Plant. 

The Tonawanda Laboratory is known to have handled smaller quantities of unprocessed African 

ores as a pilot program for the production facility, particularly in the period from October 11, 1943 

through December 15, 1943 (Jenness, undated). The documentary evidence is supplemented by 

1976 borehole measurement data of soil contamination that show radium levels that do not exceed 

background levels, an indication that African ores were not a significant contaminant around 
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Building 14, in contrast to samples taken in the area of the Ceramics Plant, which show elevated 

radium levels in the first few feet of soil in many places. Because there is no evidence of an 

increased radium source-term for soils near this section of tunnel, NIOSH believes that a 10 pCi/L 

radon level that has been established for surface buildings in the Ceramics Plant will be bounding 

for worker exposures during the SEC-00154 petition period. 

7.6 Summary of Feasibility Findings for Petition SEC-00154

This report evaluates the feasibility for completing dose reconstructions for employees at the Linde 

Ceramics Plant from November 1, 1947 through December 31, 1953. NIOSH found that the available 

monitoring records, process descriptions and source term data are insufficient to complete dose 

reconstructions for the evaluated class of employees.

Table 7-5 summarizes the results of the feasibility findings at the Linde Ceramics Plant for each 

exposure source during the time period November 1, 1947 through December 31, 1953. 

Table 7-1: Summary of Feasibility Findings for SEC-00154

November 1, 1947 through December 31, 1953

Source of Exposure Reconstruction Feasible Reconstruction Not Feasible

Internal1

 - U (total) and associated

 Progeny excluding radon

X

 - Radon X

External

 - Gamma X

 - Beta X

 - Neutron X (1950-1953)

 - Occupational Medical X-ray X

Note:

1 Internal includes an evaluation of urinalysis (in vitro) and airborne dust data. 

 Although NIOSH found that it is not possible to completely reconstruct radiation doses for the 

proposed class, NIOSH intends to use any internal and external monitoring data that may become 

available for an individual claim (and that can be interpreted using existing NIOSH dose 

reconstruction processes or procedures). Therefore, dose reconstructions for individuals employed at 

Linde Ceramics Plant during the period from November 1, 1947 through December 31, 1953, but who 

do not qualify for inclusion in the SEC, may be performed using these data as appropriate. 

8.0 Evaluation of Health Endangerment for Petition SEC-00154

The health endangerment determination for the class of employees covered by this evaluation report is 

governed by both EEOICPA and 42 C.F.R. § 83.13(c)(3). Under these requirements, if it is not 
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feasible to estimate with sufficient accuracy radiation doses for members of the class, NIOSH must 

also determine that there is a reasonable likelihood that such radiation doses may have endangered the 

health of members of the class. Section 83.13 requires NIOSH to assume that any duration of 

unprotected exposure may have endangered the health of members of a class when it has been 

established that the class may have been exposed to radiation during a discrete incident likely to have 

involved levels of exposure similarly high to those occurring during nuclear criticality incidents. If 

the occurrence of such an exceptionally high-level exposure has not been established, then NIOSH is 

required to specify that health was endangered for those workers who were employed for a number of 

work days aggregating at least 250 work days within the parameters established for the class or in 

combination with work days within the parameters established for one or more other classes of 

employees in the SEC. 

The NIOSH evaluation did not identify evidence from the petitioner or from other resources that 

would establish that the class was exposed to radiation during a discrete incident likely to have 

involved exceptionally high level exposures. The evidence reviewed in this evaluation indicates that 

some workers in the class may have accumulated substantial chronic exposures through episodic 

intakes of radionuclides. Consequently, NIOSH has specified that health was endangered for those 

workers covered by this evaluation who were employed for a number of work days aggregating at 

least 250 work days, occurring solely under this employment or in combination with work days within 

the parameters established for one or more other classes of employees in the Special Exposure Cohort. 

9.0 Class Conclusion for Petition SEC-00154

Based on its full research of the class under evaluation, NIOSH found that it cannot estimate radiation 

doses with sufficient accuracy for a class which includes all employees who worked at the Linde 

Ceramics Plant in Tonawanda, New York during the period from November 1, 1947 through 

December 31, 1953. 

NIOSH has carefully reviewed all material sent in by the petitioner, including the specific assertions 

stated in the petition, and has responded herein (see Section 7.4). NIOSH has also reviewed available 

technical resources and many other references, including the Site Research Database (SRDB), for 

information relevant to SEC-00154. In addition, NIOSH reviewed its NOCTS dose reconstruction 

database to identify EEOICPA-related dose reconstructions that might provide information relevant to 

the petition evaluation. 
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10.0 References 

42 C.F.R. pt. 81, Guidelines for Determining the Probability of Causation Under the Energy 

Employees Occupational Illness Compensation Program Act of 2000; Final Rule, Federal 

Register/Vol. 67, No. 85/Thursday, p 22,296; May 2, 2002; SRDB Ref ID: 19391 

42 C.F.R. pt. 82, Methods for Radiation Dose Reconstruction Under the Energy Employees 

Occupational Illness Compensation Program Act of 2000; Final Rule; May 2, 2002; SRDB Ref ID: 

19392 

42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as Members of the Special 

Exposure Cohort Under the Energy Employees Occupational Illness Compensation Program Act of 

2000; Final Rule; May 28, 2004; SRDB Ref ID: 22001 

42 U.S.C. §§ 7384-7385 [EEOICPA], Energy Employees Occupational Illness Compensation 

Program Act of 2000, as amended

AEC, 1947-1950a, Miscellaneous Reports of Uranium and Fluorine Urinalysis Data for Linde 

Ceramics Workers; U.S. Atomic Energy Commission (AEC); various dates from 1947-1950; SRDB 

Ref ID: 11148, pdf pp. 1-29 

AEC, 1947-1950b, Miscellaneous Reports of Uranium and Fluorine Urinalysis Data for Linde 

Ceramics Workers; U.S. Atomic Energy Commission (AEC); various dates from 1947-1950; SRDB 

Ref ID: 8955, pdf pp. 1-48

AEC, 1947-1951, Ceramics Plant Air Dust Samples; U.S. Atomic Energy Commission (AEC); 

various dates throughout the time period from 1947 through 1951; SRDB Ref ID: 8956 

AEC, 1949, NYDO Radiological Laboratory Film Badge Report for Ceramics Plant for Week 

Beginning March 28; U.S. Atomic Energy Commission (AEC); 1949; SRDB Ref ID: 3965, pdf p. 2

AEC, 1951, Urine Sample Reports 1949-1952; U.S. Atomic Energy Commission (AEC); March 2, 

1950; SRDB Ref ID: 10387, pdf p. 17 

AEC, 1954a, Various Dust Samples; U.S. Atomic Energy Commission (AEC); various dates 

throughout 1954; SRDB Ref ID: 9132 

AEC, 1954b, Various Equipment Smears; U.S. Atomic Energy Commission (AEC); various dates 

throughout 1954; SRDB Ref ID: 9137 

Aerospace Corporation, 1981, Evaluation of the 1943-to-1946 Liquid Effluent Discharge from the 

Linde Air Products Company; The Aerospace Corporation; December 1981; SRDB Ref IDs: 16979, 

pdf pp. 805-875; 8829; and 16512 

Affidavits, 2009, Affidavits from Former Linde Ceramics Employees; November 2009; OSA Ref ID: 

110180, pdf pp. 18-22 and 27-29 
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Anderson, 1945, Sludges Stored on Haist Property as of 1 May 1945, correspondence to Captain 

Russell E. Harris; Roy V. Anderson; June 13, 1945; SRDB Ref ID: 15426, pdf p. 3 

Argonne, 1987, Proposed Remedial Actions at Four FUSRAP Sites in New York, selected pages; 

Argonne National Laboratory (Argonne); July 1987; SRDB Ref ID: 16847, pdf pp. 24-29 

Army Corps, 1998, Demolition of Linde FUSRAP Site Building 30 Complete, News Release #98-46; 

U.S. Army Corps of Engineers, Buffalo District; September 21, 1998; SRDB Ref ID: 14577 

Army Corps, 2002, Dose Assessment for the Existing Surface Contamination Within the Linde Utility 

Tunnel Complex, FUSRAP Linde Remedial Action; U.S. Army Corps of Engineers, Buffalo District; 

January 2002; SRDB Ref ID: 49892 

Bechtel, 1982, Preliminary Engineering Evaluation of Remedial Action Alternatives for the Linde Air 

Products Site in Tonawanda, New York; Bechtel National, Inc.; November 1982; SRDB Ref ID: 

14704 

Bechtel, 1990, Health and Safety Plan for the Remedial Investigation/Feasibility Study-Environmental 

Impact Statement for Linde Air Products, 129-HSP-01 DRAFT; Bechtel National, Inc. (Bechtel); 

April 1990; SRDB Ref ID: 46311 

Bechtel, 1993, Remedial Investigation Report for the Tonawanda Site, DOE/OR/21949-300 Volume 

1; Bechtel National, Inc. (Bechtel); February 1993; SRDB Ref ID: 16304 and SRDB Ref ID: 9009 

Belmore, 1954, Contract No. AT-30-l-Gen-165, Amendment 15, Dated October 31, 1953, 

correspondence to Paul B. Pew; F. M. Belmore; May 5, 1954; SRDB Ref ID: 35732, pdf pp. 15-17 

Blatz, 1949, Report on a General Radiation Survey at Linde Air Products Company, Div. of Union 

Carbide & Carbon Corp, Ceramics Plant, Tonawanda, memorandum to files; H. Blatz; April 19, 

1949; SRDB Ref ID: 8836, pdf p. 18 

Correspondence, 2009a, Request for Personal Records, correspondence; [Name Redacted]; July 22, 

2009; OSA Ref ID: 110180, pdf pp. 23 

Correspondence, 2009b, Response to a Request for Personal Records, correspondence; [Name 

Redacted]; August 19, 2009; OSA Ref ID: 110180 pdf pp. 24-26 

Coutts, 2005, Data Collection Request #206-Utility Tunnel Exterior Characterization in Excavation 

Areas D2 and M South, correspondence to James Boyle; Peter W. Coutts of Shaw Environmental, 

Inc.; January 7, 2005; SRDB Ref ID: 82865 

Eckerman, 1993, External Exposure to Radionuclides in Air, Water, and Soil, Federal Guidance 

Report No. 12; Keith F. Eckerman and Jeffrey C. Ryman; September 1993; SRDB Ref ID: 11997 

Ferry, 1944, Medical Survey of the Linde Ceramics Plant, memorandum to the Area Engineer, John L. 

Ferry; March 21, 1944; SRDB Ref ID: 8980, pdf pp. 3-8 

Film Badge Dataset, 1948-1949, Linde Film Badge Dataset; file is dated September 1984; SRDB Ref 

ID: 4111 
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Frame, 1981, Radiological Survey of the Liquid Effluent Disposal Pathways Formerly Used by Linde 

Air Products Division (Union Carbide Corporation) Tonawanda, New York; P. W. Frame, J. D. 

Berger, C. F. Riemke, L. A. Young, W. O. Helton, R. D. Condra, and C. F. Weaver; October 8, 1981; 

SRDB Ref ID: 8828 

Harris, 1952, Dismantlement of Linde Air Products Co., Contract No. AT-(30-1)-GEN-165, Radiation 

Survey of November 17-20, 1952, memorandum to F. B. Belmore, U.S. Army Corps of Engineers, 

December 19, 1952; SRDB Ref ID: 11142, pdf pp 15-17, 22-23 and SRDB Ref ID: 14829 

Harris, 1954, Decontamination of Linde Air Products Co., Contract No. AT-(30-1)-GEN-165, 

Radiation Survey of April 11-15, 1954, correspondence to R. L. Kirk; W. B. Harris, U.S. Atomic 

Energy Commission, New York Operations Office; April 23, 1954; SRDB Ref ID: 11142, pdf pp. 2-6 

Hayden, 1948, Dust Hazards at Linde Air Products Ceramics Plant, correspondence to Merril 

Eisenbud; R. E. Hayden; May 27, 1948; SRDB Ref ID: 9839, pdf p. 178 

Heatherton, 1947, Progress Report, Health Physics Department for Seven Day Period Through 

December 18, 1947; R. C. Heatherton; December 21, 1947; SRDB Ref ID: 7665, pdf p. 90 

Heatherton, 1948a, Health Physics Department Progress Report for Seven Day Period Through April 

2, 1948; R. C. Heatherton; April 12, 1948; SRDB Ref ID: 14524, pdf pp. 106-107 

Heatherton, 1948b, Health Physics Department Progress Report for Seven Day Period Through April 

16, 1948; R. C. Heatherton; April 19, 1948; SRDB Ref ID: 14524, pdf p. 105

Heatherton, 1948c, Health Physics Department Progress Report for Seven Day Period Through April 

30, 1948; R. C. Heatherton; May 3, 1948; SRDB Ref ID: 14524, pdf pp. 103-104 

Heatherton, 1948d, Monthly Report, Health Physics for January 1948, L.A.P. Contract W7401Eng. 

14, correspondence to Medical Advisor's Office (Office of New York Directed Operations); R. C. 

Heatherton; February 16, 1948; SRDB Ref ID: 16979, pdf pp. 90-92 

Heatherton, 1948e, Health Physics Department Progress Report for Seven Day Period Through 

February 6, 1948; R. C. Heatherton; February 9, 1948; SRDB Ref ID: 7665, pdf pp. 77-78 

Heatherton, 1948f, Dust Samples Taken in Step III, correspondence to E. C. Kent; R. C. Heatherton; 

July 13, 1948; SRDB Ref ID: 8866 

Heatherton, 1949a, Progress Report for Seven Day Period Through May 6, 1949; R. C. Heatherton; 

May 9, 1949; SRDB Ref ID: 14524, pdf p. 18 

Heatherton, 1949b, Progress Report for Seven Day Period Through July 15, 1949; R. C. Heatherton; 

July 18, 1949; SRDB Ref ID: 14524, pdf pp. 5-6 

Heatherton, 1949c, Progress Report for Seven Day Period Through July 22, 1949; R. C. Heatherton; 

July 25, 1949; SRDB Ref ID: 7678, pdf pp. 3-4 
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Heatherton, 1949d, Progress Report for Seven Day Period Through June 10, 1949; R. C. Heatherton; 

June 13, 1949; SRDB Ref ID: 7678, pdf p. 12 

Heatherton, 1949e, Progress Report for Seven Day Period Through June 17, 1949; R. C. Heatherton; 

June 20, 1949; SRDB Ref ID: 7678, pdf pp. 10-11 

Heatherton, 1949f, Progress Report for Seven Day Period Through May 20, 1949; R. C. Heatherton; 

May 23, 1949; SRDB Ref ID: 7678, pdf pp. 15-16 

Heatherton, 1950, Decontamination and Survey of Uranium Refinery Plant, NYO-1536; Richard C. 

Heatherton; December 14, 1950; SRDB Ref ID: 29822 

Hurland, 1946, Possible Hazards at Linde Ceramics and Electro-Metallurgical Plants, 

correspondence, John Hurland; November 19, 1946; SRDB Ref ID: 88728 

Jenness, undated, Summary of Research, Development, and Pilot Plant Operation at the Laboratory of 

the Linde Air Products Company, Tonawanda, New York October 1942 to November 1945; L. G. 

Jenness and Reid Ewing; undated; SRDB Ref ID: 3744, pdf pp. 30-33 

Kent, 1947, Plant Progress Report, September – 1947, correspondence to A. R. Holmes; E. C. Kent; 

October 1, 1947; SRDB Ref ID: 8954, pdf pp. 212-220 

Kent, 1948a, Regarding Dust Hazards in the Ceramics Plant, correspondence to F. M. Belmore; E. C. 

Kent; July 13, 1948; OSA Ref ID: 105687, pdf p. 66 

Kent, 1948b, Ceramics Plant Progress Report for Week Ending April 26, 1948; E. C. Kent; April 26, 

1948; SRDB Ref ID: 9839, pdf pp. 62-64 

Kent, 1948c, Ceramics Plant Progress Report for Week Ending April 18, 1948; E. C. Kent; April 19, 

1948; SRDB Ref ID: 16979, pdf pp. 7-10 

Kent, 1949a, Ceramics Plant Progress Report for Week Ending March 27, 1949; E. C. Kent; March 

28, 1949; SRDB Ref ID: 9839, pdf pp. 145-147 

Kent, 1949b, Ceramics Plant Progress Report for Week Ending July 24, 1949; E. C. Kent; July 26, 

1949; SRDB Ref ID: 16979, pdf pp. 31-33 

Kent, 1949c, Ceramics Plant Progress Report for Week Ending November 27, 1949; E. C. Kent; 

November 28, 1949; SRDB Ref ID: 16979, pdf pp. 37-38 

Kent, 1950a, Ceramics Plant Progress Report for Ten Day Period Ending February 28,1950; E. C. 

Kent, February 28, 1950; SRDB Ref ID: 16979, pdf pp. 40-41 

Klevin, 1948, Linde Air Products Occupational Exposure to Radioactive Dust, Conducted October 

26, 1948-November 2, 1948; P. B. Klevin; January 25, 1949; SRDB Ref ID: 9119 

Klevin, 1949, Linde Air Products, Ceramics Plant Occupational Exposure to Radioactive Dust, 

August 1, 1949; Paul B. Klevin; August 26, 1949; SRDB Ref ID: 8857 
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Klevin, 1954a, Decontamination of Buildings Used for Processing Alpha Emitters; Paul B. Klevin, 

William B. Harris, and Hanson I. Blatz; April 29, 1954; SRDB Ref ID: 14830 

Klevin, 1954b, Results of General Air Samples During Decontamination Operations at the Step III 

Plant, correspondence to H. Hayward; Paul B. Klevin; May 3, 1954; SRDB Ref ID: 35732, pdf p. 20 

Linde, undated, Linde Air Products, Tonawanda, two page summary; undated; SRDB Ref ID: 16979, 

pdf pp. 45-46 

Logbook, 1947-1949, Handwritten Logbook of Blood and Urine Sample Personnel Information; 

various dates in 1947-1949; SRDB Ref ID: 21810 

Malone, 1956, Removal of Waste at Haist Property, memo to F. R. Dowling; F. W. Malone; May 29, 

1956; SRDB Ref ID: 61978 

NIOSH, 2005, SEC Petition Evaluation Report for Petition SEC-00044, Linde Ceramics Plant; 

National Institute for Occupational Safety and Health; October 12, 2005; SRDB Ref ID: 82265 

OCAS-PR-004, Internal Procedures for the Evaluation of Special Exposure Cohort Petitions, Rev. 0; 

Office of Compensation Analysis and Support (now Division of Compensation Analysis and 

Support); September 23, 2004; SRDB Ref ID: 32022 

ORAU, 1981; Interviews with Former Linde Employees; Oak Ridge Associated Universities (ORAU); 

various dates throughout 1981; SRDB Ref ID: 3745 

ORAUT-OTIB-0019, Analysis of Coworker Bioassay Data for Internal Dose Assignment, Rev. 01; 

Oak Ridge Associated Universities (ORAU) Team Dose Reconstruction Project for NIOSH; October 

7, 2005; SRDB Ref ID: 19438 

ORAUT-OTIB-0024, Estimation of Neutron Dose Rates from Alpha-Neutron Reactions in Uranium 

and Thorium Compounds, Rev. 00; Oak Ridge Associated Universities (ORAU) Team Dose 

Reconstruction Project for NIOSH; April 7, 2005; SRDB Ref ID: 19445 

ORAUT-OTIB-0070, Dose Reconstruction During Residual Radioactivity Periods at Atomic 

Weapons Employer Facilities, Rev. 00; Oak Ridge Associated Universities (ORAU) Team Dose 

Reconstruction Project for NIOSH; March 10, 2008; SRDB Ref ID: 41603 

ORAUT-OTIB-0079, Guidance on Assigning Occupational X-Ray Dose UNDER EEOICPA for XRays Administered Off Site, Rev. 00; Oak Ridge Associated Universities (ORAU) Team Dose 

Reconstruction Project for NIOSH; January 3, 2011; SRDB Ref ID: 89563 

ORAUT-TKBS-0025, An Exposure Matrix for Linde Ceramics Plant (Including Tonawanda 

Laboratory), Rev. 02; Oak Ridge Associated Universities (ORAU) Team Dose Reconstruction Project 

for NIOSH; July 15, 2011; SRDB Ref ID: 99725 

ORNL, 1978, Formerly Utilized MED/AEC Sites Remedial Action Program—Radiological Survey of 

the Former Linde Uranium Refinery, Tonawanda, New York, W-7405-ENG-26; Oak Ridge National 

Laboratory (ORNL); May 1978; SRDB Ref ID: 14620 
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Personal Communication, 2010a, Telephone Interview by ORAU Team; March 4, 2010; SRDB Ref 

ID: 80052 

Personal Communication, 2010b, Telephone Interview by ORAU Team; March 4, 2010; SRDB Ref 

ID: 80053 

Personal Communication, 2010c, Telephone Interview by ORAU Team; March 10, 2010; SRDB Ref 

ID: 80055 

Personal Communication, 2010d, Telephone Interview by ORAU Team; March 10, 2010; SRDB Ref 

ID: 80054 

Personal Communication, 2010e, Telephone Interview by ORAU Team; March 11, 2010; SRDB Ref 

ID: 80056 

Petition, 2009, Linde Ceramics Special Exposure Cohort Application: November 1, 1947 through 

December 31, 1953; SEC petition; received November 5, 2009; OSA Ref ID: 110180 

Rennich, 1947, Uranium-Thorium Branch Semi-Annual Report to Congress, correspondence to E. M. 

Velten; George Rennich; December 1, 1947; SRDB Ref ID: 10256, pdf pp. 8-11 

Robinson, 1945, Sludge and P-V Cake to be Stored on the Haist Property, correspondence to Captain 

R. E. Harris; Berwyn M. Robinson; July 16, 1945; SRDB Ref ID: 15426, p. 4 

Robinson, 1973, African Metals Corporation Residues; Robinson; March 6, 1973; SRDB Ref ID: 

14800 

Sample Log Sheets, 1947-1961, Handwritten Sample Log Sheets for Various Sample Types for 

Various Sites, includes Linde Ceramics Plant; U. S. Atomic Energy Commission, New York Office 

Radiological Laboratory; various dates in 1947-1961; SRDB Ref ID: 11452, pdf pp. 500-591 

SC&A, 2006, Draft Review of the NIOSH Site Profile for the Linde Ceramics Plant and Tonawanda 

Laboratory, Tonawanda, New York; S. Cohen & Associates (SC&A); July 14, 2006; SRDB Ref ID: 

37635 

SC&A, 2009, Draft Assessment of the Disposition of SC&A’s Linde Site Profile Review Issues in 

Response to SEC Petitioner Concerns, supporting document provided by the petitioner; S. Cohen & 

Associates (SC&A); August 2009; OSA Ref ID 110180, pdf pp. 30-103 

SEC-00107 E-mail, 2004, Request and Response Regarding Information on Linde Site Cleanup and 

Remediation, E-mail chain with attachment; September 29, 2004 through October 8, 2004; SRDB Ref 

ID: 14580 

SEC-00107 Interview, 2008a, SEC-00107 Linde Ceramics Plant Interviews – [Name Redacted], 

supporting document provided by the petitioner; Interview conducted in support of SEC-00107; 

September 11, 2008; OSA Ref ID: 110180, pdf pp. 13-14
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SEC-00107 Interview, 2008b, SEC-00107 Linde Ceramics Plant Interviews – [Name Redacted], 

supporting document provided by the petitioner; Interview conducted in support of SEC-00107; 

September 11, 2008; OSA Ref ID: 110180, pdf pp. 15-17 

SEC Petition Narrative, 2008, Linde Ceramics SEC Petition Application: November 1, 1947 through 

December 31, 1953, supporting document provided by the petitioner; March 28, 2008; OSA Ref ID: 

105724 

Supplementary Evidence, 2008a, Linde Ceramics SEC Petitions Addendum SEC Tracking Numbers: 

SEC00106 and SEC00107—Additional Issues and Supplementary Evidence Supporting Linde 

Ceramics Petitions SEC00106 and SEC00107; March 19, 2008; OSA Ref ID: 105723 

Supplementary Evidence, 2008b, Additional Issues and Supplementary Evidence Supporting Linde 

Ceramics SEC Petitions SEC00106 November 1, 1947 through December 31, 1953 and SEC00107 

January 1, 1954 through July 31, 2006, supporting document from the petitioner; April 25, 2008; 

OSA Ref ID: 105849 

Supplementary Evidence, 2008c, Additional Issues and Supplementary Evidence Supporting Linde 

Ceramics SEC Petition SEC00107 January 1, 1954 through July 31, 2006, supporting document from 

the petitioner; May 2008; OSA Ref ID: 106080 

Thornton, 1976, Haist Property Fact Sheet; William T. Thornton; June 28, 1976; SRDB Ref ID: 

15431 

Weinstein, 1954, Results of Decontamination Survey of the Step III Building Conducted During the 

Period of February 9-11, 1954, correspondence to H. Hayward; Martin S. Weinstein; March 10, 1954; 

SRDB Ref ID: 11142, pdf pp. 7-14 

Wolf, 1948, Results of Uranium and Fluoride Analyses, correspondence to R. C. Heatherton; B. S. 

Wolf; February 27, 1948; SRDB Ref ID: 16979, pdf. pp. 96-98 

Wolf, 1949, Material Handling, correspondence to E. O. Kent; B. S. Wolf; March 16, 1949; SRDB 

Ref ID: 16316, pdf pp. 17-18 
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Attachment One

Attachment One: Data Sources on Uranium Progeny Concentrations in Linde Materials

Data Sources on Uranium Progeny Concentrations in Linde Materials

SRDB 

Ref ID Date Location Description U238

U234U235 Total U Th-230 Ra226Th232Th228Ac227Pa231 Units Th230/URa226/UTh232/U Ac/U Pa/U

16294 1995 Bldg. 14 dry valve pit (dust) 1038 1068 53.8 2159.8* 354.7 15.3 2.3 1.7 pCi/g 0.16* 0.01* 0.00*

sump (dust) 1.4 1.7 0.07 3.17* 0.72 0.52 0.2 0.22 pCi/g 0.23* 0.16* 0.06*

corridor overhead (dust) 369 378.8 11.6 759.4* 60.2 0.14** 5 0.67 pCi/g 0.08* 0.00* 0.01*

corridor wall (terra cotta block) 3.2 3.2 0.14 6.54* 1.7 1.4 1.4 1.4 pCi/g 0.26* 0.21* 0.21*

14620 1978 Bldg. 30 air samples during D&D 1.90E-08 2.10E-09 1.10E

-09 pCi/ml 0.11* 0.06* 0.00*

9009 1981 Sediment,

onsite & 

offsite

Ellicott Creek 0.82 0.05 1.69* 0.6 0.55 0.7 pCi/g 0.36* 0.33* 0.41*

Creek 1 0.95 0.05 1.95* 0.7 0.7 0.8 pCi/g 0.36* 0.36* 0.41*

Twomile Creek-upstream 4.3 0.1 8.7* 0.92 0.69 0.01 pCi/g 0.11* 0.08* 0.00*

Twomile Creek-Linde discharge 0.71 0.06 1.48* 0.02 0.52 0.02 pCi/g 0.01* 0.35* 0.01*

Twomile Creek-downstream 1.5 0.05 3.05* 0.96 0.59 0.48 pCi/g 0.31* 0.19* 0.16*

Storm Sewer 6.47 0.19 13.13* 1.4 1.35 0.62 pCi/g 0.11* 0.10* 0.05*

Storm Sewer 99 4.57 202.57* 18 6.93 0.51 pCi/g 0.09* 0.03* 0.00*

Storm Sewer 13 0.52 26.52* 2 1.59 0.65 pCi/g 0.08* 0.06* 0.02*

Storm Sewer 116 4.1 236.1* 9.9 0.89 0.34 pCi/g 0.04* 0.00* 0.00*

Storm Sewer 4.5 0.17 9.17* 0.2 0.64 0.39 pCi/g 0.02* 0.07* 0.04*

Sanitary Sewer 362 13 737* 1.33 1.94 0.11 pCi/g 0.00* 0.00* 0.00*

Sanitary Sewer 0.51** 0.05 1.07* 0.34 0.38 0.21 pCi/g 0.32* 0.36* 0.20*

9026 1990 Linde soil area 1-mean 11.2 22.4* 7.8 4.3 1.6 pCi/g 0.35* 0.19* 0.07*

area 2-mean 12.7 25.4* 5.7 3.4 1.4 pCi/g 0.22* 0.13* 0.06*

area 3-mean 17.1 34.2* 24.4 9.4 1.4 pCi/g 0.71* 0.27* 0.04*

area 4-mean 46.8 93.6* 30.7 9.8 1.4 pCi/g 0.33* 0.10* 0.01*

8828 1981 Linde soil 

& 

sediment

near disposal well-subsurface (loc 

11) 24.05 0.84 48.94* 5.9 5.53 0.92 14.25 0.73 pCi/g 0.12* 0.11* 0.02* 0.29* 0.01*

test well debris (loc 13) 26.4 1.09 53.89* 3.53 0.82 0.51 2.1 0.29** pCi/g 0.07* 0.02* 0.01* 0.04* 0.01*

sanitary sewer (loc 15) 362 12.9

3 736.93* 1.33 1.14 0.11 5.54 0.95 pCi/g 0.00* 0.00* 0.00* 0.01* 0.00*

storm sewer (loc 19) 99.2 4.57 202.97* 17.7 6.93 0.51 14.29 1.14 pCi/g 0.09* 0.03* 0.00* 0.07* 0.01*

storm sewer (loc 21) 116 4.1 236.1* 3.89 0.89 0.34 3.07 0.39** pCi/g 0.02* 0.00* 0.00* 0.01* 0.00*

Notes:

* calculated value

** <MDA, MDA shown
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Attachment Two

Attachment Two: Data Capture Synopsis

Table A3-1: Data Capture Synopsis for Linde Ceramics Plant

Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded to 

SRDB

Primary Site/Company Name: Linde Ceramics Plant

AWE/DOE* 1942-1953; Res. Rad. 1954-1987; 1993-1995; 

1997-July 2006; DOE 1988-1992; 1996 (remediation)

 

Other Site Names: 

Linde Air

Praxair 

Documents relating to the renovation of Building 30, amendments to 

New York State radioactive materials license 1983-0143. 

01/27/2010: A request was sent to Karen Ginnane, Praxair Site 

Manager, for any documents relating to the tunnels under Buildings 14 

and 30, and documents that would clarify the completion date for the 

early AEC decontamination of the site. She has found some documents 

pertaining to the tunnels. The documents are undergoing a review by 

Praxair's General Counsel's Office. 

Open item 19

State Contacted: Robert Snyder of the New York State 

Bureau of Environmental Radiation Protection and 

Environmental Exposure Investigations confirmed that the 

NYS records are their copies of DOE and US ACE 

FUSRAP reports. 

No relevant data not already in the SRDB identified. 10/02/2008 0

City of Tonawanda Public Library No data from the operational period identified. 03/11/2010 0

Claimant New York State assembly report on military sources of Buffalo area 

contamination, public meetings, FUSRAP characterization of Building 

14, Building 31 remediation, FUSRAP documents, hearing transcripts, 

and epidemiologic studies.

04/18/2005 20

Department of Energy (DOE) HQ, Germantown Report of Blixt-Massett sludge dumping, hazard assessments, internal 

dosimetry data and procedures, source term data, waste disposal 

records, AEC licensing material, accountability reports, and thorium 

processing reports.

03/05/2004 13

Department of Labor/Paragon Progress reports, Tonawanda area site plans, a description of 

Tonawanda area residues, LOOW FUSRAP plans which refer to Linde 

residues.

12/30/2008 33

DOE EML/HASL Trip reports. 03/08/2005 1

DOE Legacy Management - Grand Junction Office Health physics reports, progress reports, dust sample results, shipping 

data, FUSRAP reports, medical hazards of radium-containing sludges, 

and a vicinity property survey.

01/18/2010 149
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Attachment Two

Table A3-1: Data Capture Synopsis for Linde Ceramics Plant

Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded to 

SRDB

DOE Legacy Management - MoundView (Fernald 

Holdings, includes Fernald Legal Database)

Epidemiology studies, 1950 survey, waste processing reports, LOOW 

characterization which mentions Linde as a source of stored residues, 

and a production report.

05/21/2008 9

DOE Oak Ridge Operations Vault Environmental surveys of vicinity properties and mobile gamma 

scanning, process information including African ores, process 

knowledge interviews, job descriptions and schedules, epidemiologic 

studies with reviews and responses, former employee searches, health 

physics reports, and external exposure data. 

NOTE: A review of holdings in the ORO vault on 03/08/2010 did not 

uncover any additional relevant records.

03/08/2010 51

DOE OSTI (Physical Data Capture) Results of ORNL independent verification surveys of Buildings 14 and 

31 and a survey of irradiation facilities.

09/25/2006 3

Federal Records Center - Kansas City Remediation period bioassay, contamination survey, and air sampling 

results, FUSRAP health and safety plans, and Tonawanda area history.

03/06/2009 75

Internet - Comprehensive Epidemiologic Data Resource 

(CEDR)

No relevant data identified. 01/15/2010 0

Internet - Department of Labor EEOICPA circular modifying the covered facility building definitions. 12/26/2007 1

Internet - DOE Hanford Declassified Document Retrieval 

System (DDRS)

No relevant data identified. 01/15/2010 0

Internet - DOE Legacy Management Considered Sites 

Database

Mobile gamma scanning results. 10/25/2007 1

Internet - DOE OpenNet An NYOO progress report for January 1949, Manhattan District 

History, Book I, Volume 7, and Linking Legacies. 

NOTE: These documents were added by site association reviews on 

10/22/2008 and 03/13/2010.

01/15/2010 3

Internet - DOE OSTI Energy Citations No relevant data identified. 01/15/2010 0

Internet - DOE OSTI Information Bridge Stannard's Radioactivity and Health, FUSRAP reports on recycling, 

innovative technical approaches to remediation, and soil 

characterization.

01/15/2010 4

Internet - Google Uranium enrichment newsletter, DOE finding aid, safety of Linde 

residues at LOOW, report on determining remediation goals, and media 

coverage of remediation.

03/22/2010 19

Internet - National Academies Press (NAP) No relevant data identified. 01/15/2010 0
SEC-00154 11-22-11 Linde Ceramics Plant

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Attachment Two

Table A3-1: Data Capture Synopsis for Linde Ceramics Plant

Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded to 

SRDB

Internet - National Nuclear Security Administration 

(NNSA) - Nevada Site Office

No relevant data identified. 03/22/2010 0

Internet - NRC Agencywide Document Access and 

Management (ADAMS)

Emails regarding USACE planned final soil remediation levels and the 

dismissal of a stakeholder group lawsuit.

01/15/2010 2

Internet - U.S. Army Corps of Engineers FUSRAP project updates, records of decision, links to site boundary 

monitoring, and a discussion of final remediation goals for soil 

contamination. 

07/14/2008 16

Internet - Washington State University (U.S. Transuranium 

and Uranium Registries)

No relevant data identified. 01/15/2010 0

Missouri Department of Natural Resources St. Louis area documents which mention Linde residues and FUSRAP 

activities.

10/03/2008 2

NARA Atlanta Process information, inspections, internal dosimetry data, dust sample 

data, radiological surveys, procedures, progress reports, hazard 

assessments, accident reports, shipping and receiving reports, 

accountability reports, product sample analyses, and external dosimetry 

results.

06/20/2008 211

NARA Kansas City Historical information on Afrimet residues, solid waste treatment data, 

contract closeout with 11/17/1952 radiation survey, historical 

information on Linde residues at LOOW, and a decontamination report.

06/24/2005 8

NIOSH Review of the site profile, addition of a class to the SEC, decision to 

change building status, process knowledge interviews, and notice of the 

commencement of the CERCLA five-year review.

01/25/2010 13

ORAU Team Exposure matrices, ORAU Project spreadsheet, documented process 

knowledge interviews, dust and gas samples, medical procedures, 

personnel records including medical records, health physics reports, 

work reports, remedial investigation reports, dust and contamination 

surveys, and FUSRAP documents.

12/07/2009 54

R.S. Landauer Radiation dosimetry reports for remediation workers, 2000-2003. 08/19/2008 1

Sanford Cohen & Associates (SC&A) SC&A assessment of NIOSH response to TBD issues and process 

knowledge interview notes.

02/05/2010 6

Savannah River Site (SRS) Dosimetry visitors cards from the 1950s. 08/26/2008 1

Southern Illinois University Observations on early uranium exposures from an ERDA report. 10/18/2008 1

University of California, San Diego 1941 letter informing Columbia University that Linde could not supply 

a uranium dioxide requirement.

Unknown 1
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Attachment Two

Table A3-1: Data Capture Synopsis for Linde Ceramics Plant

Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded to 

SRDB

Unknown Process information, liquid effluent data, procedures, epidemiologic 

data, process knowledge interviews, safety and health requirements for 

residue handling, personnel medical records, external dosimetry data, 

source term and accountability data, health physics reports, DOE 

remediation surveys and plans, dust samples, occupational exposures to 

airborne dust, health hazards at NYOO uranium facilities, and 

Tonawanda area reports.

12/06/2004 74

TOTAL 791

Table A3-2: Database Searches for Linde Ceramics Plant

Database/Source Keywords / Phrases Hits Uploaded to 

SRDB

CEDR

http://cedr.lbl.gov/

COMPLETED 01/15/2010

Linde Ceramics in title

Tonawanda in Title

Linde Air

Linde

2 0

DOE Hanford DDRS

http://www2.hanford.gov/declass/

COMPLETED 01/15/2010

Linde Ceramics in title

Tonawanda in Title

Linde Air in Title

Linde in any field

110 0

DOE OpenNet

http://www.osti.gov/opennet/advancedsearch.jsp

COMPLETED 01/15/2010

Linde Ceramics in Title

Tonawanda in Title

Linde Ceramics in full text

Linde Ceramics" in full text

Linde Air Products in full text

Linde in any field

233 3
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Attachment Two

Table A3-2: Database Searches for Linde Ceramics Plant

Database/Source Keywords / Phrases Hits Uploaded to 

SRDB

DOE OSTI Energy Citations

http://www.osti.gov/energycitations/

COMPLETED 01/15/2010

"Linde Ceramics" in any field

Linde Ceramics in any field

Tonawanda in Title

Linde in any field 

2,492 0

DOE OSTI Information Bridge

http://www.osti.gov/bridge/advancedsearch.jsp

COMPLETED 01/15/2010

"Linde Ceramics" in any field

Linde Ceramics in any field

Tonawanda in any field

"Linde Ceramics" in title

"Linde Air Products" in title

"Linde Air Products" in any field

"Linde" in any field

1,992 4 

Google

http://www.google.com

COMPLETED 03/22/2010

"Linde Ceramics"

"Linde Ceramics" oralloy

"Linde Ceramics" postum

"Linde Ceramics" tuballoy

"Linde Ceramics" "uranyl nitrate hexahydrate" OR UNH

"Linde Ceramics" "K-65"

"Linde Ceramics" "sump cake"

"Linde Ceramics" "uranium dioxide"

"Linde Ceramics" "uranium tetrafluoride"

"Linde Ceramics" "uranium trioxide"

"Linde Ceramics" "uranium hexafluoride"

"Linde Ceramics" accident

"Linde Ceramics" "air count"

"Linde Ceramics" "air dust"

"Linde Ceramics" "air filter"

116,999 19
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Attachment Two

Table A3-2: Database Searches for Linde Ceramics Plant

Database/Source Keywords / Phrases Hits Uploaded to 

SRDB

"Linde Ceramics" alpha

"Linde Ceramics" "belgian congo ore"

"Linde Ceramics" bioassay OR "Linde Ceramics" bio-assay

"Linde Ceramics" breath OR "Linde Ceramics" "breathing zone" OR 

"Linde Ceramics" BZ

"Linde Ceramics" calibration

"Linde Ceramics" columnation

"Linde Ceramics" contamination

"Linde Ceramics" curie

"Linde Ceramics" "denitration" OR "Linde Ceramics" "denitration pot"

"Linde Ceramics" derby OR "Linde Ceramics" regulus

"Linde Ceramics" dose

"Linde Ceramics" dosimeter

"Linde Ceramics" dosimetric

"Linde Ceramics" dosimetry

"Linde Ceramics" electron

"Linde Ceramics" environment

"Linde Ceramics" "Ether-Water Project"

"Linde Ceramics" exposure OR "Linde Ceramics" "exposure 

investigation" OR "Linde Ceramics" "radiation exposure"

"Linde Ceramics" external
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Attachment Two

Table A3-2: Database Searches for Linde Ceramics Plant

Database/Source Keywords / Phrases Hits Uploaded to 

SRDB

"Linde Ceramics" "F machine"

"Linde Ceramics" fecal

"Linde Ceramics" "feed material"

"Linde Ceramics" femptocurie

"Linde Ceramics" film

"Linde Ceramics" fission

"Linde Ceramics" fluoroscopy

"Linde Ceramics" "Formerly Utilized Sites Remedial Action Program" 

OR "Linde Ceramics" FUSRAP

"Linde Ceramics" gamma-ray

"Linde Ceramics" "gas proportional"

"Linde Ceramics" "gaseous diffusion"

"Linde Ceramics" health OR "Linde Ceramics" "health instrument" OR 

"Linde Ceramics" "health physics" OR "Linde Ceramics" H.I. OR 

"Linde Ceramics" HI OR "Linde Ceramics" HP

"Linde Ceramics" "highly enriched uranium" OR "Linde Ceramics" 

HEU

"Linde Ceramics" hydrofluorination

"Linde Ceramics" "in vitro"

"Linde Ceramics" "in vivo"

"Linde Ceramics" incident

"Linde Ceramics" ingestion

"Linde Ceramics" inhalation

"Linde Ceramics" internal
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Attachment Two

Table A3-2: Database Searches for Linde Ceramics Plant

Database/Source Keywords / Phrases Hits Uploaded to 

SRDB

“Linde Ceramics" investigation

"Linde Ceramics" isotope

"Linde Ceramics" isotopic

"Linde Ceramics" "isotopic enrichment"

"Linde Ceramics" "JS Project"

"Linde Ceramics" Landauer

"Linde Ceramics" "liquid scintillation"

"Linde Ceramics" log OR "Linde Ceramics" "log sheet" OR "Linde 

Ceramics" "log book"

"Linde Ceramics" "low enriched uranium" OR "Linde Ceramics" LEU

"Linde Ceramics" "maximum permissible concentration" OR "Linde 

Ceramics" MPC

"Linde Ceramics" metallurgy

"Linde Ceramics" microcurie

"Linde Ceramics" millicurie

"Linde Ceramics" "mixed fission product" OR "Linde Ceramics" MFP

"Linde Ceramics" monitor OR "Linde Ceramics" "air monitoring"

"Linde Ceramics" nanocurie

"Linde Ceramics" "nasal wipe"

"Linde Ceramics" neutron

"Linde Ceramics" "nose wipe"

"Linde Ceramics" nuclear OR "Linde Ceramics" "Chicago-Nuclear" OR 

"Linde Ceramics" "nuclear fuels"
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Attachment Two

Table A3-2: Database Searches for Linde Ceramics Plant

Database/Source Keywords / Phrases Hits Uploaded to 

SRDB

"Linde Ceramics" "nuclear track emulsion" OR "Linde Ceramics" "type 

A" OR "Linde Ceramics" NTA

"Linde Ceramics" "occupational radiation exposure"

"Linde Ceramics" occurrence

"Linde Ceramics" "ore concentrate"

"Linde Ceramics" "PC Project"

"Linde Ceramics" "phosphate research"

"Linde Ceramics" photon

"Linde Ceramics" picocurie

"Linde Ceramics" pitchblende

"Linde Ceramics" "pocket ion chamber" OR "Linde Ceramics" PIC

"Linde Ceramics" problem

"Linde Ceramics" permit OR "Linde Ceramics" "radiation work permit" 

OR "Linde Ceramics" "safe work permit" OR "Linde Ceramics" 

"special work permit" OR "Linde Ceramics" RWP OR "Linde 

Ceramics" SWP

"Linde Ceramics" "retention schedules"

"Linde Ceramics" procedure

"Linde Ceramics" radeco

"Linde Ceramics" radiation

"Linde Ceramics" radioactive

"Linde Ceramics" radiograph

"Linde Ceramics" radiological

"Linde Ceramics" "Radiological Survey Data Sheet" OR "Linde 

Ceramics" RSDS
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Attachment Two

Table A3-2: Database Searches for Linde Ceramics Plant

Database/Source Keywords / Phrases Hits Uploaded to 

SRDB

"Linde Ceramics" radeco

"Linde Ceramics" radiation

"Linde Ceramics" radioactive

"Linde Ceramics" radiograph

"Linde Ceramics" radiological

"Linde Ceramics" "Radiological Survey Data Sheet" OR "Linde 

Ceramics" RSDS

"Linde Ceramics" radionuclide

"Linde Ceramics" raffinate

"Linde Ceramics" reactor

"Linde Ceramics" respiratory

"Linde Ceramics" roentgen

"Linde Ceramics" sample OR "Linde Ceramics" "air sample" OR 

"Linde Ceramics" "dust sample" OR "Linde Ceramics" "general area air 

sample"

"Linde Ceramics" sampling OR "Linde Ceramics" "air sampling" OR 

"Linde Ceramics" "dust sampling" OR "Linde Ceramics" "general area 

air sampling"

"Linde Ceramics" "solvent extraction"

"Linde Ceramics" source OR "Linde Ceramics" "sealed source"

"Linde Ceramics" spectra

"Linde Ceramics" spectrograph

"Linde Ceramics" spectroscopy

"Linde Ceramics" spectrum
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Attachment Two

Table A3-2: Database Searches for Linde Ceramics Plant

Database/Source Keywords / Phrases Hits Uploaded to 

SRDB

"Linde Ceramics" standard OR "Linde Ceramics" "operating standard" 

OR "Linde Ceramics" "processing standard"

"Linde Ceramics" survey "building survey" OR "Linde Ceramics" 

"routine survey" OR "Linde Ceramics" "special survey"

"Linde Ceramics" "technical basis"

"Linde Ceramics" "thermal diffusion"

"Linde Ceramics" "Tiger Team"

Linde Ceramics" "thermoluminescent dosimeter" OR "Linde Ceramics" 

TLD

"Linde Ceramics" "tolerance dose"

"Linde Ceramics" urinalysis

"Linde Ceramics" urine

"Linde Ceramics" "whole body count" OR "Linde Ceramics" WBC

"Linde Ceramics" "working level" OR "Linde Ceramics" WL

"Linde Ceramics" "X-ray" OR "Linde Ceramics" "X ray" OR "Linde 

Ceramics" Xray OR "Linde Ceramics" "X-Ray Screening"

"Linde Ceramics" americium OR Am241 OR Am-241 OR "AM 241" 

OR 241Am OR 241-Am OR "241 Am"

"Linde Ceramics" ionium OR Th230 OR Th-230 OR "Th 230" OR 

230Th OR 230-Th OR "230 Th"
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Attachment Two

Table A3-2: Database Searches for Linde Ceramics Plant

Database/Source Keywords / Phrases Hits Uploaded to 

SRDB

"Linde Ceramics" neptunium OR Np237 OR Np-237 OR "Np 237" OR 

237Np OR 237-Np OR "237 Np"

"Linde Ceramics" polonium OR Po210 OR Po-210 OR "Po 210" OR 

210Po OR 210-Po OR "210 Po"

"Linde Ceramics" thorium OR Th232 OR Th-232 OR "Th 232" OR 

232Th OR 232-Th OR "232 Th" OR "Z metal" OR myrnalloy OR 

"chemical 10-66" OR "chemical 10-12" OR ionium OR UX1 OR UX2

"Linde Ceramics" Th-230 OR Th230 OR "Th 230" OR 230-Th OR 

"230 Th" OR 230Th OR Th-234 OR Th234 OR "Th 234" OR 234-Th 

OR 234Th OR "234 Th"

"Linde Ceramics" neptunium OR Np237 OR Np-237 OR "Np 237" OR 

237Np OR 237-Np OR "237 Np"

"Linde Ceramics" uranium OR U233 OR U-233 OR "U 233" OR 233U 

OR 233-U OR "233 U" OR U234 OR "U 234" OR U-234 OR 234U OR 

234-U OR "234 U" OR U235 OR "U 235" OR U-235 OR 235-U 

“Linde Ceramics" 235U OR "235 U" OR U238 OR "U 238" OR U-238 

OR 238-U OR 238U OR "238 U" OR U308 OR "U 308" OR U-308 OR 

308-U OR 308U OR 308 U OR "uranium extraction"

"Linde Ceramics" "black oxide" OR "brown oxide" OR "green salt" OR 

"orange oxide" OR "yellow cake" OR UO2 OR UO3 OR UF4 OR UF6 

OR C-216 OR C-616 OR C-65 OR C-211 OR U3O8
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Attachment Two

Table A3-2: Database Searches for Linde Ceramics Plant

Database/Source Keywords / Phrases Hits Uploaded to 

SRDB

"Linde Ceramics" plutonium OR Pu-238 OR Pu238 OR Pu 238 OR 

238Pu OR 238-Pu OR "238 Pu" OR Pu-239 OR Pu239 OR "Pu 239" 

OR 239Pu OR 239-Pu OR "239 Pu"

"Linde Ceramics" Pu-240 OR Pu240 OR "Pu 240" OR 240Pu OR 240-

Pu OR "240 Pu" OR Pu-241 OR Pu241 OR "Pu 241" OR 241Pu OR 

241-Pu OR "241 Pu"

"Linde Ceramics" radium OR Ra-226 OR Ra226 OR Ra 226 OR 226-

Ra OR 226Ra OR 226-Ra OR Ra-228 OR Ra228 OR Ra 228 OR 

228Ra OR 228-Ra OR 228 Ra

"Linde Ceramics" radon OR Rn-222 OR Rn222 OR Rn 222 OR 222Rn 

OR 222-Rn OR 222 Rn

"Linde Ceramics" thoron OR Rn-220 OR Rn220 OR "Rn 220" OR 

220Rn OR 220-Rn OR "220 Rn"

"Linde Ceramics" protactinium OR Pa-234m OR Pa234m OR "Pa 

234m" OR 234mPa OR 234m-Pa OR "234m Pa"

"Linde Ceramics" strontium OR Sr-90 OR Sr90 OR "Sr 90" OR 90-Sr 

OR 90Sr OR "90 Sr"

Linde Ceramics

"Linde Ceramics" AND "Tunnel"

"Linde Air" AND "Utility Tunnel"

"Linde" AND "Utility Tunnel"

"Ceramics Plant" AND "Tunnel"

"linde site" AND "1950"
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Attachment Two

Table A3-2: Database Searches for Linde Ceramics Plant

Database/Source Keywords / Phrases Hits Uploaded to 

SRDB

"linde site" AND "Decontamination" AND "1953"

"linde site" AND "Decontamination" AND "1950"

"linde site" AND "Remediation" AND "1953"

"linde site" AND "Remediation" AND "1950"

"tonawanda" AND "utillity tunnel"

"union carbide" AND "utility tunnel" AND "Linde"

"building 14" AND "linde site"

"linde plant" AND "building 14"

"linde plant" AND "building 30"

"linde" AND "AEC"

Praxair

Praxair and Linde

National Academies Press

http://www.nap.edu/

COMPLETED 01/15/2010

"Linde Ceramics"

Linde Ceramics

Tonawanda

"Linde Air Products"

Linde

440 0

NNSA - Nevada Site Office

www.nv.doe.gov/main/search.htm

COMPLETED 03/22/2010

"Linde Ceramics"

Tonawanda

Linde

Praxair

0 0

NRC ADAMS Reading Room

http://www.nrc.gov/reading-rm/adams/web-based.html

COMPLETED 01/15/2010

"Linde Ceramics" in title

Linde Ceramics in title

Tonawanda in Title

Linde Tonawanda

Linde in any field

957 2
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Attachment Two

Table A3-2: Database Searches for Linde Ceramics Plant

Database/Source Keywords / Phrases Hits Uploaded to 

SRDB

U.S. Transuranium & Uranium Registries 

http://www.ustur.wsu.edu/

COMPLETED 01/15/2010

Tonawanda

Linde

0 0

Table A3-3: OSTI Documents Requested for Linde Ceramics Plant

Document Number Document Title Requested

Date

Received

Date

OSTI ID 4371773 Proposed Method of Production of High Purity Uranium Ore 

Concentrates

01/15/2010

OSTI ID 6883076 Composition of Linde E95 (AW500) Zeolite Fraction of Sludge 02/02/2010

OSTI ID 10146442 Travel to the Development Library of Linde Air Products Company for 

Discussions Concerning the Welding of Unbounded Pieces, Trip 

Report, January 15, 1952

02/02/2010